Where drugs are found in a vehicle driven by the accused who holds the keys, physical custody or control is established even though another person also has access to the vehicle. However, knowledge that the drugs are present cannot be established beyond reasonable doubt merely by proof that the accused drove the car and had the keys, where there is evidence that another person who is a drug user also regularly used the vehicle and had personal items in it. Lies told by the accused to police about the car cannot be used as evidence of consciousness of guilt where there is a reasonable hypothesis that the lies were told to protect a family member known to be involved in drug use.
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