The giving of a Calides direction should be cautiously entered upon and carefully crafted to fit the summing up as a whole; it should not be uncritically tacked on at the end of a summing up. A direction using only the third limb of Calides, integrated into standard burden of proof directions, may be preferable to the full three-limb formulation. A Liberato direction is not required in every oath against oath case provided the summing up as a whole makes clear that nothing short of proof beyond reasonable doubt will suffice.
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