The Court held that a Liberato direction is not required where the accused does no more than make a bare denial of allegations (as distinct from offering an alternative version of events), and that magistrates, being entirely familiar with the onus and standard of proof, need not routinely give themselves such a direction. On the substantive appeal, the Court set aside two common assault convictions where the complainant's evidence was uncorroborated, having found that her credibility was so significantly damaged that her evidence should not be accepted unless independently corroborated. Convictions for forcible confinement, assault occasioning actual bodily harm, and property damage were confirmed where photographic evidence provided substantial corroboration.
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