A jury direction to scrutinise 'the evidence relating to duress' with great care does not contravene Robinson v R where the direction is addressed to all evidence on the issue rather than singling out the accused's evidence by reference to his interest in the outcome. However, the Victorian Court of Appeal has indicated that such directions should no longer be given in duress cases, as they are unnecessary. The dissent's reasoning — that where a defence depends solely on the accused's evidence, directing scrutiny of the defence is in substance directing scrutiny of the accused's evidence — remains a live issue.
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