A direction that the standard of proof 'is not beyond any doubt' is undesirable but does not constitute a misdirection where the summing up as a whole adequately conveys the beyond reasonable doubt standard. Evidence of flight may be left to the jury as capable of evidencing consciousness of guilt even where the accused has advanced a plausible alternative explanation, provided the evidence is not intractably neutral and the jury is directed that they must be satisfied beyond reasonable doubt that there is no other reasonable explanation for the flight.
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