A direction that indispensable intermediate facts must be proved beyond reasonable doubt is not required where the circumstantial evidence consists of numerous facts of varying probative force ('strands in a cable') rather than a few essential facts ('links in a chain'). The test for whether a fact is 'indispensable' is whether, in the absence of evidence of that fact, there would nonetheless be a case to go to the jury. The 'usually essential' formulation in R v Merritt may not be consistent with subsequent High Court authority in Velevski, Hillier and Keenan.
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