THE pre-trial right of a suspect to remain silent in the face of police questioning and the law on the admissibility of confessions have in recent years been the subject of detailed scrutiny and criticism by numerous law reform bodies. The present article seeks to examine in detail the recommendations of two such bodies. These are the proposals of the English Royal Commission on Criminal Procedure' and the Australian Law Reform Commission on Criminal Investigation.2 While the common law rules relating to the right to remain silent and the admissibility of confessions are essentially the same in both countries, the approaches taken by the two Commissions are diametrically opposed. For this reason, a detailed comparative examination of their proposals may serve to highlight with particular clarity both the defects and underlying rationales of the existing rules of the law and practice in these two areas. Part I of this article will deal with the right of a suspect to remain silent in the face of police questioning. Part II will deal with the admissibility of confessions. At the end of each part an overall comparative appraisal of the reform strategy of the two Commissions will be presented. In Part III a fundamental criticism, common to both reports, will be advanced, and an attempt will be made to point in the