In sexual assault cases turning on conflicting evidence, the trial judge must give a Liberato direction telling the jury that even if they do not positively believe the defence evidence, they cannot find against the accused if that evidence gives rise to a reasonable doubt. Directions on complaint evidence must specifically identify its relevance to the credibility of the complainant, not merely refer to 'consistency of conduct'. An Edwards direction on lies must require the jury to first determine whether a lie was in fact told before considering whether it was deliberate. An aggregate of errors in jury directions, even if individually insufficient, may together constitute a miscarriage of justice.
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