A trial judge's direction informing the jury of the effect of s 37A of the Sentencing Act 1995 (WA) in relation to an accomplice witness is appropriate and in the interests of justice where it assists the jury's understanding of the accomplice's self-interest. It is not always necessary for a trial judge to direct a jury that a co-offender's guilty plea is not evidence admissible against the accused; the need for such a direction depends on whether there is a real (as distinct from fanciful) risk of the jury using the plea impermissibly. A 20-year minimum non-parole period for murder involving a sudden, unprovoked strangulation attack on a defenceless victim, followed by dumping the body and concealment, was within the proper sentencing range.
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