In Boardman v. D.P.P., [1975] A.C. 421, the terms "a close or striking similarity" and "a uniquely or strikingly similar manner" were used. The use of the words "striking" and "strikingly" is perhaps unfortunate for they tend to suggest a high degree of similarity rather than a degree of similarity that would strike one as being relevant for the particular purpose for which the evidence is offered.
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