Evidence of uncharged loans that is led to establish an accused's financial position, rather than as evidence of uncharged criminal conduct, does not require a mandatory Gipp-type warning. Where the Crown does not rely on lies as evidence of consciousness of guilt but the trial judge introduces the topic, the direction must not prejudice the accused, but a full Edwards direction is not necessarily required if the direction given adequately warns the jury that lies do not necessarily indicate guilt. A total sentence of seven and a half years for fraud offences involving just under $73,000 was manifestly excessive.
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