A [name withheld] direction is not required as a matter of law in every case where there is a conflict between the evidence of an accused and a complainant. There is no mandatory form of words for such a direction; the question is whether, having regard to the summing up as a whole, there was a real risk the jury would have been left with the impression that disbelief of the accused's evidence or preference for the complainant's evidence meant the State had proved its case beyond reasonable doubt.
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