The recording of a plea of guilty entered by counsel is unlikely to constitute a 'judgment or order' amenable to correction under the slip rule (UCPR r 36.17); the proper course is to apply to withdraw the plea. The test in R v Ho requiring an 'error of principle apt to cause irregularity or injustice' for the grant of leave under s 5F(3) may not reflect the current law, but this question was left open.
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