The offence of 'making a false document' under s.83A(1) of the Crimes Act 1958 (Vic) requires proof that the document 'tells a lie about itself' — that is, it purports to be something it is not — and not merely that it contains false statements. Trial judges must carefully explain this distinction to juries, particularly where the issue is who was responsible for inserting false information into a document signed by another person. Where a document has been signed by the purported maker, the Crown must establish that the document was materially altered after signing without the signer's knowledge or authorisation.
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