A trial judge who provides written directions to the jury in the form of a question trail must, at a minimum, orally read and explain those directions during the summing up. Failure to do so constitutes a miscarriage of justice, even where the trial judge identifies the 'real issue' in the case orally but does not address the elements of the offence set out in the written directions. The principle applies even where the victim was shot from behind and the trial judge suggested the jury would have 'little difficulty' with the element of intention.
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