When post-offence conduct (flight and disposal of weapon) is relied on by the prosecution as proof of guilt of murder, the trial judge is not required to specifically direct the jury that the conduct could have stemmed from consciousness of guilt of manslaughter rather than murder. It is sufficient that the judge directs the jury that they must be satisfied beyond reasonable doubt that the conduct sprang from a realisation of guilt of murder and not from some other cause such as panic, fear, or concern that actions were foolish and dangerous. There is no rigid formula for such directions; each case depends on its own facts.
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