Dalam kes D.A Duncan v P.P [1980] 2 MLJ 195, Mahkamah Persekutuan memutuskan penilaian berhubung keterangan bare denial tertuduh dengan menyatakan: “Now this evidence, if accepted and believed, is clearly sufficient to establish a prima facie case against the appellant. The High Court at Alor Star accepted it and called on the defence. The defence was, in effect, a simple denial of the evidence connecting the appellant with the four boxes. We cannot see any plausible ground for saying that the four boxes were not his. In the circumstances of the prosecution evidence, the High Court came, in our view, to the correct conclusion that this denial did not cast a doubt on the prosecution case against the appellant.”