Implied Assertion Approach
R v Twists and Others 
Court of Appeal strongly recommended avoidance of the usage of the concept of implied assertion as the Criminal Justice Act 2003 focusing on matter stated which need to be proven. The following suggestions are considered while considering whether hearsay rule applicable or not.
a) recognising the relevant fact / matter to be sought
b) does the statement relating to the fact / matter to be sought contained in the communication
c) if no there will be no issue of hearsay
d) if yes whether that was one of the purpose of the maker of the communication to cause others to believe the matter and acting upon it. In this case, it will account for hearsay.