1. He has been asked to Appear as a witness for the defence

2. In principle every person who is competent to be a witness is Compellable. In criminal proceedings, the spouse or civil partner of the accused is generally competent and Compellable as a witness for the defence.

3. ‘At the date of the appellant's trial he was a Compellable witness for the defence and there is no reason to believe he was unavailable.’ ‘There was no other way of eliciting this evidence because the maker of the statements was not a Compellable witness for the co-defendant.’