State v. Mahlon J. Gravelle, 89 A.2d 111, 117 Vt. 238 (Vt. 1952)
Models, maps, plans and photographs belong, in the law of evidence, to the same class, and are admissible only when properly verified. That is to say, preliminary evidence is required to show that they are sufficiently accurate to be helpful to the jury. But this preliminary evidence is addressed to the court,--the preliminary question of the sufficiency of the verification, though a question of fact, is for the determination of the court and is not ordinarily reviewable. Hassam v. Safford Lumber Co., 82 Vt. 444, 449, 74 A. 197. The whole question of the admissibility of photographs is one largely in the discretion of the trial court and the rulings thereon are not ordinarily reviewable. Leland v. Leonard, 95 Vt. 36, 38, 112 A. 198; Goulette's Admr. v. Grand Trunk Ry. Co., 93 Vt. 266, 271, 107 A. 118; Hutchinson v. Knowles, 108 Vt. 195, 204, 184 A. 705; State v. Frotten, 114 Vt. 410, 417, 46 A.2d 921. Changes in the premises between the time of the occurrence and the time of the taking of photographs do not necessarily operate to exclude the latter. Changes in the conditions are open to explanation. Aldrich v. Boston & Maine Railroad, 91 Vt. 379, 384, 100 A. 765; Dent, Admr. v. Bellows Falls & Saxtons River St. Ry. Co., 95 Vt. 523, 533, 116 A. 83; State v. Longe, 96 Vt. 7, 9, 116 A. 81. [117 Vt. 242] Under the offer here and as received in connection with the witness' testimony, the photographs were not independent evidence but merely to aid the jury to a proper understanding of the testimony of the witness. Hassam v. Safford Lumber Co., supra, at 448; Neill v. Ward, 103 Vt. 117, 159, 153 A. 219.
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