This case has been followed by R v Walker,[9] where an individual accused of shoplifting attempted to adduce expert evidence of their condition, which it was claimed made them more vulnerable to threats of duress. While the case was described as borderline by the Court of Appeal, it was decided that such evidence could be properly admitted where it was not commonly found in ordinary individuals. A strict approach to such evidence has faced criticism in some cases, with the decision of R v Masih[10] highlighting how a borderline case may be difficult for the courts.