The timing and repetition of warnings under ss 306X and 306ZI of the Criminal Procedure Act 1986 (NSW) regarding pre-recorded and remote evidence remain within the trial judge's discretion; there is no rule requiring warnings immediately before or after the evidence. The use of the word 'independent' in complaint evidence directions, while erroneous and to be avoided following SB v R, does not necessarily constitute a miscarriage of justice where the direction in context would not have misled the jury.
The full text is available to signed-in members, including the 6 later cases that cite this judgment.
2 of the 6 citing cases carry a classified treatment. How each court treated it is available to signed-in members.