A trial judge's reference to media reports about the Royal Commission into Institutional Responses to Child Sexual Abuse, when commenting on delay in complaint in a child sexual abuse trial, is undesirable but does not occasion a miscarriage of justice where subsequent directions adequately instruct the jury to scrutinise the complainant's evidence due to delay and explain the forensic disadvantages to the defence. The Dhanhoa test — whether it is reasonably possible the comments affected the verdict — is to be applied by considering the impugned comments in the context of the summing up as a whole.
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