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The defendant had been charged with attempting to obtain property by deception by fabricating his death by drowning in the sea off Miami in Florida. The final act alleged to constitute the offence occurred outside the jurisdiction of the English courts.Held: The charge was justiciable in England. The defendant appealed conviction on counts of attempted obtaining by deception on the ground, among others, of judicial misdirection in the following words: ‘There is an attempt by the accused within the legal meaning of that word ‘attempt’ if you are satisfied that the matters I have stated to you are proved.’

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