The failure to use the specific expressions 'dangerous to convict' or 'scrutinise the evidence with care' does not amount to an error of law in every case of delay in complaint. The adequacy of delay directions depends on the summing up as a whole and the circumstances of the particular case, including the extent of delay and the concatenation of prejudicial factors. Where the trial judge has given general and specific warnings about prejudice from delay and a judicial caution about reliance on a single witness, the absence of a formal 'dangerous to convict' warning may not render the trial unfair.
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