We used to have a right to silence in England. Our current Miranda equivalent police caution says:

> 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.

We also tend not to have "loopholes" - someone not getting the correct caution will have to go through years of expensive law . Their case isn't won just because of a missing warning. (I think; I am not a lawyer.)

It's a shame. Right to silence may have started here: (https://en.wikipedia.org/wiki/Miranda_warning#England_and_Wa...)

But is being attacked here: (https://en.wikipedia.org/wiki/Right_to_silence_in_England_an...)