A trial judge cannot direct a jury that an accused is criminally responsible for acts of others merely because those others were 'under his control'; the Crown must establish complicity through the established doctrines of acting in concert, aiding and abetting, or counselling and procuring. The case also confirms that where lies are blatant and may be treated by the jury as an indispensable link in the chain of evidence, it is preferable to direct the jury that they must be satisfied beyond reasonable doubt that the lies constitute an implied admission of guilt. The terminology 'consciousness of guilt' is criticised as potentially misleading; 'implicating evidence' or 'evidence tending to implicate the accused' is suggested as preferable.
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