A trial judge's direction requiring the jury to be satisfied beyond reasonable doubt that the accused 'deliberately' performed the relevant act adequately addresses the defence of unwilled act under s 23A of the Criminal Code (WA), without the need to use the statutory language of 'willed' or 'unwilled'. Cases not falling within the worst category of doing grievous bodily harm with intent commonly attract sentences within the range of 4½ to 8 years' imprisonment.
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