The Palmer principle requiring protection against reversal of the onus of proof through motive-to-lie reasoning applies not only to cross-examination but equally to closing addresses and the summing up. Where a trial judge puts to the jury that there is no evidence of a motive for the complainant to lie, a direction that the defence bears no onus of establishing such a motive is essential. The combination of a Palmer misdirection with concerns about the Liberato direction may together constitute a miscarriage of justice even where neither alone would be sufficient.
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