When jury tampering has occurred at a prior trial, a trial judge has broad discretion to order special jury protection measures including transportation arrangements, sequestration during deliberations, and in camera proceedings. Such orders require exceptional and special circumstances but do not of themselves prevent a fair trial, provided the judge takes care to minimise the obviousness of precautions and gives appropriate directions. Pre-trial publicity that does not identify the accused and is several months old is unlikely to warrant a stay.
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