California, United States of America
The following excerpt is from Ng v. Hudson, 142 Cal.Rptr. 69, 75 Cal.App.3d 250 (Cal. App. 1977):
Assuming that an instruction may be refused because it was tendered orally, it is nevertheless within the discretion of the court to waive defects in the tender of proposed instructions. In Young v. Carlson (1954) 128 Cal.App.2d 743, 746, 276 P.2d 23, the court held that it was within the discretion of the judge to either accept or refuse instructions tendered after the time limit imposed by section 607a. The judge should have similar discretion to entertain oral requests for instructions where justice and reason permit.
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