The test of immediacy in duress does not require that the threat be carried out at the moment of compliance; it requires proximity between the threat and the criminal act, and a belief that the threat will be executed when the threatener is first able to give effect to it. The objective test for duress requires consideration of the subjective characteristics of the accused, including age, sex, and history of prolonged domestic violence. Expert psychological evidence about the effects of domestic violence is admissible and must be considered in assessing both the accused's demeanour and the question of whether a person of reasonable firmness sharing the accused's characteristics would have yielded to the threat.
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