The impermissibility of 'why would the complainant lie?' questions established in Palmer v R extends to police video interviews, not just cross-examination at trial. However, where experienced defence counsel acquiesces in the admission of such evidence for tactical reasons and the trial judge gives clear and specific directions to the jury about the dangers of such questions, the admission may not constitute a miscarriage of justice. The question remains whether judicial directions can ever be sufficient to cure the prejudice — the dissent held they cannot, following Palmer's doubt about the efficacy of such directions.
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