Non-compliance with s 192(2) of the Criminal Procedure Act 1986 (NSW) — the requirement that the court state the substance of the offence to the accused — does not of itself invalidate a guilty plea. Where the accused is represented by a legal practitioner who is aware of the charges, the purpose of s 192(2) can be achieved without formal stating of charges in court. However, for unrepresented accused persons, explicit compliance with s 192(2) will generally be required for a valid plea.
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