A trial judge's direction that post-offence conduct cannot be used as consciousness of guilt is insufficient where the prosecution's case in substance relies on that conduct to prove intent, and the jury would inevitably treat it as evidence of guilty mind. A full Edwards direction must be given in relation to all post-offence conduct from which the jury could draw an inference of consciousness of guilt, not merely in relation to specific identified lies. The avoidance of the term 'consciousness of guilt' by the prosecution does not remove the need for the direction.
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