The three considerations for withdrawal of a guilty plea identified in R v Wilkes operate sequentially: if the plea is found to be attributable to consciousness of guilt, the 'real question about guilt' consideration does not arise as a separate ground. The fact that the Crown may be unable to prove its case (e.g., because witnesses refuse to testify) goes to proof of guilt and does not of itself raise a real question about guilt sufficient to support withdrawal of a plea.
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