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R. v. Raphael s/o Yohanes, Crim. Rev. 3-D-67; 7/1/67; Mustafa, J.
Accused was convicted of escape from lawful custody (P. C. s.116) on evidence that he ran away from a policeman while allegedly showing him where stolen goods had been hidden.
Held: Although it was shown that accused was physically in the presence of an officer, the prosecution had the burden of showing that accused had been placed under arrest at the time he fled.
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