A trial judge's direction describing complaint evidence as 'independent' of the complainant's oral evidence does not occasion a miscarriage of justice where the direction is understood in context as meaning 'separate from' the oral evidence at trial, and is qualified by a warning that repetition does not make a statement more reliable. The word 'independent' should be avoided in future directions but its use is not necessarily erroneous. When reviewing aggregate sentences for manifest excess, the principal focus is whether the aggregate sentence reflects the total criminality involved, not whether individual indicative sentences are excessive.
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