When voluntariness is in issue and left to the jury, the trial judge must not direct the jury that 'one starts with the proposition that acts are willed and voluntary and conscious'; rather, the jury must be directed that the prosecution bears the onus of proving beyond reasonable doubt that the act was voluntary. The use of 'intentional' interchangeably with 'voluntary' and 'conscious' when directing on the actus reus creates an unacceptable risk of confusion between general and specific intent, particularly where offences with different mental elements are tried together.
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