An Edwards direction regarding lies or post-offence conduct is not required where the prosecutor uses such evidence only to attack the credibility of the defence hypothesis rather than as an implied admission of guilt, even if the prosecutor uses isolated language suggestive of consciousness of guilt. The need for such a direction must be assessed against the particular circumstances of each case, including the strength of the independent evidence, the centrality of the post-offence conduct to the Crown case, and whether there is a real risk the jury would engage in impermissible reasoning. Where the Crown case rests on abundant direct evidence and post-offence conduct is merely one item undermining the defence, the risk of misuse is considerably reduced.
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