Prior to the Northern Ireland (Emergency Provisions) Act 1973 coming into force, Lowry excluded confessions made by Provisional Irish Republican Army (IRA) suspects in British Army detention on the grounds that they were not made voluntarily.
Lowry did not exclude self-incriminating evidence alone as insufficient to convict upon, and in R v. Gorman[REF] he found that the Northern Ireland Act 1972 s. 1, by retrospectively validating the conferment of powers of arrest under the regulations, rendered lawful the otherwise unlawful arrest and subsequent detention of Gorman.