When directing a jury on provocation, the personal characteristics of the accused must be conveyed as relevant to assessing the gravity of provocation under the objective test, not merely the subjective test. The 'reasonable possibility' method of directing on provocation — asking whether there is a reasonable possibility that provocation caused the accused to lose self-control and that an ordinary person might have done likewise — is usually to be preferred. 'Might' and 'could' are synonymous in this context, and 'might' is the safer word to use in oral directions.
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