In Western Australia, jury directions on dangerous driving under s 59(1)(b) of the Road Traffic Act 1974 (WA) should follow the objective McBride/Jiminez test without reference to the perception of an ordinary person in the position of the accused. A Liberato direction is not required where the case does not involve conflicting accounts between prosecution and defence witnesses and the accused's own evidence contains inculpatory elements. For multiple counts of dangerous driving occasioning death arising from the same incident, some accumulation of individual sentences is appropriate to mark the overall criminality of causing multiple deaths.
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