statemnet he gave to the police. It would have meant him

admitting before all the world that, because he was

temporarily without work, he was willing to engage in

robbing someone who had, at one time, been his own client.

8.

There should have been no dispute on the basic

facts which are as set out in paragraph 4 of the Petition

for Special Leave, Exh. 3, to which Your Petitioner craves

leave to refer. These were the facts on the Crown's own

evidence and as set out by the Court of Appeal in Hong Kong

in dismissing his Appeal.

0.

Your Petitioner further humbly craves leave to

refer in particular to paragraphs 13 and 15 of the said

Petition for Special Leave and re-affirms that it was not

his intention in any way that his companions should kill or do

grievous bodily harm to Mr. Teyfour, the said deceased. The

plan, as evidenced from his own statement to the police

itself, was to tie Mr. Teyfour up should he come in. Your

Petitioner also repeats that the whole purpose of him not

coming on the robbery to the Hong Kong Hotel was because

otherwise he could be identified afterwards by the man who

was robbed, i.e. Mr. Teyfour.

10.

Crown Counsel obviously had the same impression

of the evidence as Lord Russel in the Privy Council, because

before Your Petitioner's trial started the said Crown Counsel

offered to accept a plea of guilty from Your Petitioner to

manslaughter and robbery, which was communicated to Your

Petitioner by this then counsel. For a reason similar to

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