R v Hay (1860) was an English robbery trial argued by R.S. Nolan as suggesting a narrow priest-peninent privilege in England and Wales exists, such that the court did not require the priest to disclose any conversation which may have occurred, but on the facts of the case, imprisoned him for not stating who handed a stolen item to him by way of restitution to the victim of a robbery, the priest not having denied he knew the identity of the person who handed it to him.
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