A trial judge's direction on lies must comply with all four requirements summarised in Osland v The Queen: (1) precise identification of the lie and the circumstances said to indicate it constitutes an admission; (2) instruction that the lie may only be taken into account if it reveals knowledge of the offence; (3) instruction that there may be innocent reasons for lying; and (4) instruction that if an innocent reason is accepted, the lie cannot be regarded as an admission. Merely directing the jury that a lie must be 'material' to the investigation, without explaining that it must reveal knowledge of the offence, is insufficient. The direction on alternative innocent reasons must go beyond 'feeling trapped' to include panic, escaping unjust accusation, protecting others, and avoiding extraneous consequences.
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