The Court of Appeal held that introducing reasonable foreseeability into the definition of 'deliberate' act for murder was erroneous in Victoria, as this concept applies only in Code states. The Court also held that police evidence of an overheard admission made during a telephone call to a friend required a warning about the dangers of acting on uncorroborated police evidence, even though the admission was not made directly to police. The Court confirmed that 'serious injury' for manslaughter and 'really serious injury' for murder have different meanings and should not be equated in jury directions.
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