Criminal law – Trial. The Court of Appeal, Criminal Division, in dismissing the defendant's appeal against conviction, held that the absence of a Lucas direction, in accordance with R v Lucas ([1981] 2 All ER 1008), had not rendered the defendant's convictions for various sexual offences as unsafe. In the circumstances, any attempt to have embellished the summing up with a Lucas direction would have served to confuse and complicate an essentially simple issue at trial.