A trial judge must give specific warnings about the dangers inherent in testimony based on memory recovered by hypnotherapy, including the reasons why such testimony is capable of being distorted and unreliable; a general reference to 'potential for distortion' is insufficient. This obligation does not depend on expert evidence being adduced. Verdicts based substantially on hypnotically recovered memory where the complainant's unaided recollection was extremely vague and uncertain may be set aside as unsafe and unsatisfactory.
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