Cross-examination of an accused as to the absence of motive of a complainant or witness to lie, where no specific motive has been raised in the accused's evidence or cross-examination of the complainant, is impermissible under Palmer v The Queen. Where such cross-examination occurs, the trial judge must give a direction that even if the jury rejects any suggested motive to lie, that does not mean the complainant is necessarily telling the truth, and the Crown must still satisfy the jury of the truth of the complainant's evidence. Failure to give such a direction, combined with the prosecutor's reliance on absence of motive in address, constitutes a miscarriage of justice. Separately, acquittals on some counts do not render guilty verdicts on other counts unsafe or unsatisfactory where the counts of conviction are supported by confirmatory evidence that was absent on the counts of acquittal.
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