“You are a keen golfer with a handicap of four?" said counsel to a witwitness in the Supreme Court in Auckland, and added, “Indeed, you could not have a handicap of four unless you were keen and spent a good (leal of time on it.” “I think I can take judicial notice of that,” said Mr. Justice Callan. “In fact, I would go further and say that a large number of people could never get near a four handicap, even if they played golf all day.”
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https://paperspast.natlib.govt.nz/newspapers/DOM19390325.2.172.26
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Dominion, Volume 32, Issue 154, 25 March 1939, Page 8 (Supplement)
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86Untitled Dominion, Volume 32, Issue 154, 25 March 1939, Page 8 (Supplement)
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