R. v Kadir (Abdul) [2022] EWCA Crim 1244 | [2022] 9 WLUK 159 | [2023] 1 Cr. App. R. 4
A judge presiding over a Crown Court trial could permit a witness who was outside the UK to give evidence via WhatsApp video call if satisfied that it was in the interests of justice. That was the case under the Criminal Justice Act 2003 s.51, as temporarily modified during the COVID-19 pandemic, and also under the version of s.51 which had been in force since 28 June 2022.