A trial judge's direction on the accused's failure to give evidence need not employ the precise language of Azzopardi v R (2001) 205 CLR 50, provided the direction given sufficiently conveys the substance of the warnings identified by the High Court majority as almost always desirable. For sentencing in Commonwealth revenue fraud cases, release after approximately one quarter of the head sentence is manifestly inadequate where the fraud involved deliberation, persistence, and a substantial amount.
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