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# Long description

Figure 11 is a note with the heading ‘2. Chronological’. The text says: ‘Before – R v Jogee, R v Ruddock (2016) – After. A speech bubble pointing to the text Before says: ‘R v Chan Wing-Siu [1985] set the rule as … The doctrine was crystallised in R v Powell; R v English [1999] as … Smith explains the rule was problematic because … Analyses of convictions showed …’ A speech bubble pointing to the case names R v Jogee, R v Ruddock says ‘These cases changes the law in two ways … Mansour argues that …’. A speech bubble pointing to the text After says ‘The following appeal cases demonstrate that … Subsequent research by Holmes et al. demonstrates further …’