Where a complainant says words to the effect of 'Why would I lie?' during cross-examination and the prosecutor emphasises that response in closing, the position is no better than if the prosecutor had directly asked the jury to speculate on motive, and a Palmer direction is required. A direction that the accused need not prove motive is insufficient; the jury must also be told not to speculate as to the complainant's motive and that it is unfair to expect the accused to suggest one. The complainant's evidence gains no credibility from the absence of evidence of motive to lie.
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