A trial judge's direction explaining 'conscious', 'voluntary' and 'deliberate' separately — with 'voluntary' meaning a willed act and 'deliberate' meaning not accidental — adequately conveys the defence of accident in the sense of an unwilled act, without requiring a separate direction on automatism where no such defence was advanced. The decision confirms that where a defence of unwilled act (as distinct from automatism) is raised, the standard direction on 'conscious, voluntary and deliberate act' as explained in R v Schaeffer is sufficient.
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