The Court of Criminal Appeal will take a rigorous approach to applications to add further grounds of appeal based on fresh evidence after the hearing has concluded and judgment is reserved. Rule 25A Criminal Appeal Rules does not constitute an open-ended opportunity for appellants to advance additional grounds on a rolling basis. The Court will assess such applications with considerable circumspection, having regard to the timing, the history of the appeals, and the arguability of the proposed grounds. Evidence of one indemnified witness may support the evidence of another indemnified witness, consistently with Papakosmas v The Queen.
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