Genghis
*Except* that this was apparently said to the court by his lawyer. One hopes that professionalism in a lawyer would not permit him to say that without seeing and hopefully presenting to the court, hard evidence to that effect.
On the contrary, it would be unprofessional (and incompetent) of a lawyer not to convey what he has been informed to the court .
Lawyers do not vouch for the truth or accuracy of what they have been told; they convey the client's instructions.
(If a defendant has been admitted to hospital the previous day, it is extremely unusual for a medical report to be available.)
A barrister would not be surprised by a Judge ordering that a defendant must surrender to police within an hour of being discharged from hospital – see Jonzarno's post 22 above. Such an order is to be expected; the terms of the order are likely to be stricter/allow less leeway where a defendant has been proved to have perpetrated deceptions.
Such orders usually result either in defendants attending court (having recovered sufficiently, coincidentally of course) or producing a medical report confirming that they are unfit to do so.
Nor, when a defendant does attend court, would a barrister be surprised by a Judge asking if there was medical evidence to support/confirm a defendant's claim about his condition - see again Jonzarno's post. (A defendant would be warned that such a question is inevitable.)
A Judge is likely to suspect that if such evidence was available it would have been produced or, if not available at such short notice but could be obtained given more time, say 7 days, that the barrister would have asked for the case to be adjourned for that to happen.
The judge was, apparently, quite outspoken in his response to that....
Well, what a surprise.
NB: It should not be assumed that, even if a medical report had been produced confirming Crellin's claim, it would have made any difference to the sentence imposed.