The Turnbull guidelines do not apply in cases where the prosecution seek to rely on voice identification evidence. According to Reid v R (1990), judges are required to given an even more stringent version of the Turnbull warning as it has be shown that experts giving evidence can still make mistakes.

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The Turnbull guidelines, which are designed to assist with the evaluation of identification evidence, do apply to cases involving voice identification. In Reid v R (1990), it was indeed acknowledged that voice identification can be problematic and that experts can make mistakes, but the principles of caution outlined in Turnbull are still relevant and applicable to voice identification evidence, requiring judges to warn of the need for caution.

The Turnbull Guidelines Do Not Apply in Cases Where the Prosecution