4

(a) submit that statement on p.13 of sup "It

no more than that" is a misdirection on this ground

should have been "It can be no more than that."

51

may be

-

It

(b) "the alternative is not to accept the evidence.of

Eric Davies.

Defence accepted the evidence of E. Davies.

(c)

The words "it was suggested" was a misdirection

was the definite evidence of Mrs. F. that the boy & girl

she saw thrown in by appellant were the same children she

saw rescued.

(a) & (e). (d) point not raised by Fraser but only

by C. J.

(e) That point only mentioned in Mary Pine's evidence.

Mr. Lim states he now withdraws points (d) & (e)

Court Adjourned to 10.00 a.m. on 9.10.34

it

James J. Hayden 3.10.34

9/10/34

Same counsel & Solrs. (Appellant not present)

Mr Lim refers to R. v. Buchan this was misdirection

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by way of omission. In this case 1. J. should have put

defence fairly to Jury his reference to evidence of E. Davies

was such as to dispel from minds of Jury the defence raised.

by Appellant's Col.

R. V. Hall 11 C. A.R..227 - test to be applied in

considering whether there was substantial miscarriage of

Justice.

-

Rex v. Ellsom 7 C. A.R. p.4 refers to p.11 Impossible to

say that in this case if there had been no misdirection that

the Jury would have returned same verdict.

R. v. Wann 7 C.A.R. 135 refers to p.138 on same point.

Submit no evidence on which Jury could convict in this

case. The 2 cases put up

by Defence were equally

consistent. At most Crown case mere suspicion. If bruises

on Mary Pine's neck if it had not been mentioned that

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