In prosecutions for possessing drugs for the purpose of sale under s 32 of the Controlled Substances Act 1984 (SA), evidence of large amounts of cash found on the accused's premises is admissible where, taken with other circumstantial evidence such as drugs in commercial quantities, scales, and the accused's unemployment, it tends to prove the existence of an ongoing drug business. The relevance of such evidence is not negated merely because it incidentally tends to prove past offences. The Northern Territory decision in Lewis (1989) 46 A Crim R 365, which held such evidence inadmissible as propensity evidence, is not followed in South Australia.
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