Where the Crown case goes far beyond possession of recently-stolen property and amounts to an extremely strong circumstantial case, a trial judge is not required to give a specific direction that the jury cannot convict merely on the basis of recent possession if they think the accused's explanation is reasonably possible. There is no hard and fast rule as to what period constitutes 'recent' possession; four months may qualify depending on the circumstances. Complaints about a trial judge's comments on facts during summing up will be viewed with circumspection where no objection was taken at trial.
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