The additional direction on motive to lie identified in Jovanovic and Palmer is not invariably required; where the evidence of motive comes from another witness or arises in a half-hearted way in passing, it may be sufficient that the jury has been properly instructed on the onus of proof. The defence of claim of right requires the issue to be sufficiently raised by the evidence before a direction is required, and a passing reference dismissed as a joke by the witness is insufficient. Two members of the Court signalled that the availability of claim of right as a defence to robbery with violence warrants reconsideration or legislative correction.
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