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(b) I have never made any confession or admission of
my guilt of the said offence to any person and
I have at all times, and still do, maintain my
innocence.
(c) I did not give evidence on my own behalf at my
trial but I had repeatedly given a consistent
account of my movements during the day when the
said offence occurred both to the police and to
psychiatrists questioning me at the request of the
prosecution. Had I given evidence at my trial there
would have been nothing further I could have said
in my own behalf other then what I had already told
to those persons. Further my counsel advised me
that I was adopting a proper course in deciding not
to give evidence myself and I respectfully submit
that the course that I adopted should not be held
against.me.
(d) at my trial my counsel was refused permission by the
learned trial judge to call as witness in my defence
Dr. W.L. Pang who would have given evidence:-
(i) that he was the Psychiatrist-in-charge, of the
Siu Lam Psychiatric Centre,
(ii) that at the request of the prosecution I was
remanded to that Centre for five months (October,
November, December, 1972, and January and part
of February 1973) for psychiatric examination,
(iii) that during that period I was examined by him
and two other psychiatrists on many occasions
and that I gave a consistent account of my
moments on the day of the offence and categorically
denied that I had committed that offence,
(iv) that I was also questioned under abreaction
(by the giving of a hypnotic and methedrine
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