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s136 discretion to limit evidence and s165 warning unreliable evidence Fernando v R, HEARSAY RULE - s59 Evidence of previous representation Intention of Maker = Purpose of Adducing = Hearsay Excluded unless Maker is competent, s61, First-hand Hearsay, Lee v R subject to s136 discretion to limit evidence, Relevant to Non-hearsay purpose, s60 must be still be relevant, not back door - Eastman v R - buy gun from Canberra Can use for Hearsay purpose subject R v Adam, credibility other purpose Restricted to, Maker is competent, s61 AND exception applies First-hand Hearsay, s62 Maker to see, hear, perceive - Eastman, Maker is competent, s61 AND exception applies Relevant to Non-hearsay purpose, s60 must be still be relevant, not back door - Eastman v R - buy gun from Canberra, Maker is competent, s61 AND exception applies Admissions, s81, Can use for Hearsay purpose subject R v Adam, credibility other purpose Restricted to First-hand Hearsay, Lee v R