In a multi-issue homicide trial where wilful murder is charged, an Edwards direction on post-offence conduct (lies and concealment) need not require the jury to be satisfied that the conduct was motivated by consciousness of guilt of wilful murder specifically; it is sufficient that the direction addresses consciousness of guilt of the criminal conduct alleged (the homicide) and identifies possible innocent explanations. The distinction between absence of evidence of motive and proven absence of motive remains significant: only the latter requires specific direction to the jury that it favours the accused.
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