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"Right to Silence" - British Version of Miranda Rights

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In England and Wales, the police make the following statement when arresting a person: "You do not have to say anything, but it may harm your defence if you do not mention when questioned something which you later rely on in court. Anything you do say may be given in evidence." This statement is very similar to the Miranda Rights read to those under arrest in the United States. So what's the difference?

The Fifth Amendment of the U.S. Constitution states that no one must incriminate himself or herself.  Those under arrest in the United States have the "right to remain silent" which "cannot be held against (them) in a court of law."
It seems like, in Great Britain, a person under arrest has to come up with an alibi or "defence" (defense in the U.S.) pretty quickly. American audiences of the popular television program Law and Order UK are quickly growing accustomed to hearing Great Britain's "Right to Silence" read aloud.
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