A trial judge who receives a jury note disclosing deliberative processes inter se is correct to mask those portions before disclosing the note to counsel, as the deliberations of the jury are not a matter upon which the parties can join issue. The giving of a Black direction is not precluded by the trial judge's knowledge that a minority juror is under pressure from the majority, provided the direction adequately addresses the role of the individual juror. A planned killing for financial gain where the plan inevitably involved killing the victim may attract life imprisonment under s 61(1) of the Crimes (Sentencing Procedure) Act 1999.
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