The case confirms the application of the doctrine of recent possession as stated in Bruce v The Queen, including that the absence of explanation must not itself be explicable in a manner consistent with innocence. It also illustrates the operation of the special verdict provisions under s 568(9) and (10) of the Criminal Code 1899 (Qld) where a jury is satisfied of guilt of stealing or receiving but cannot say which. On sentence, it confirms that offending while on parole and bail, combined with an extensive criminal history for like offences and no cooperation, justifies a firm sentence for personal deterrence with no claim for leniency open.
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