In prosecutions under s 409(1) of the Criminal Code (WA), it is generally inappropriate and confusing to direct the jury on s 24 (honest and reasonable mistake of fact) when the defence amounts to a denial of intent to defraud. An unreasonable belief, if genuinely held, suffices to negate intent to defraud, and introducing the concept of reasonableness from s 24 creates a real risk of the jury applying an irrelevant shortcut reasoning process.
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