A trial judge had been entitled to continue with his summing up after an attempt by the defendant to disrupt it, by escaping the dock and attacking the judge, since no fair-minded observer would conclude that continuing with the trial was unfair or perceived to be unfair. There had been no need for the judge to enquire into the effect of the defendant's actions on the jury, because it was bound to continue with the trial. If a defendant was able to stop his trial and obtain a new one by causing such disruption, it would have the potential to make trial by jury unworkable.

[2006] EWCA Crim 470

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