After Zecevic v DPP, the imminence of a threat to the accused is not a threshold legal requirement for self-defence but remains an important and often critical factual consideration relevant to whether the accused believed on reasonable grounds that it was necessary in self-defence to do what he did. A carefully planned killing carried out in response to a generalised apprehension of future harm, where the accused had not seen the deceased for a month and was not being attacked, cannot support a realistic hypothesis of self-defence, notwithstanding the profound psychological effects of prior sexual assault by the deceased.
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