The grant of a certificate under s 128 of the Evidence Act 2008 (Vic) may, depending on the circumstances, be relevant to the credibility of a witness and may properly be revealed to the jury, but the mere grant of a certificate does not necessarily put a prosecution witness into a 'very special category' enabling the defendant to say the witness is unreliable. Where the certificate is revealed, the judge should ordinarily direct the jury as to its effect, including that it does not provide immunity from prosecution and offers no protection against perjury. The Palmer principle is not infringed by the use of rhetorical questions in a prosecutor's closing address unless the form of argument has the effect of casting an obligation on the accused to answer the questions posed.
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