Where a trial judge reads the entirety of an accused's out of court statement to the jury as part of the defence case summary, no separate direction on the use of exculpatory material in that statement is required, distinguishing R v [name withheld]. The conventional expression 'grievous bodily harm' should be used in murder directions rather than 'serious bodily harm', particularly where the accused has a history of inflicting injuries that are serious but not grievous. The dissent provides a detailed analysis of the obligation to direct on manslaughter where the cause of death is strangulation and the accused has previously used violence without causing grievous bodily harm.
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