https://www.lawgazette.co.uk/law/cas...n=%20GAZ141016

In judgment, the court said the two-stage test defined in 1982 R v Ghosh, has ‘serious problems’. That case involved a surgeon who was convicted for receiving payments for work carried out by others. The second stage in the Ghosh test asks juries to consider whether the defendant would have realised that ordinary honest people would regard his behaviour as dishonest. Today's judgment says that does not correctly represent the law and that directions based on it should no longer be given.