The case confirms that a Jones v Dunkel-type direction in a criminal trial does not offend the principles in Dyers v The Queen where the trial judge directs the jury that no adverse inference should be drawn against either party and that the jury should not speculate about the evidence of uncalled witnesses. The case also confirms that post-sentencing events such as deterioration in health or prison incidents are matters for the prison authorities or the Executive, not the appellate court, unless they throw light on the true significance of factors known at sentencing.
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