Where the intent to commit the substantive offence (here, rape) would necessarily involve an intention to inflict one or more of the detriments in s 31(2)(b) of the Crimes Act 1958 (Vic), proof of the 'intermediate intention' is subsumed by proof of the intent to commit the offence, and no separate direction on the intermediate intent is required. The decision in Gipp v The Queen did not alter the unsafe and unsatisfactory verdict test established in M v The Queen.
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