Where a complainant makes a positive identification from a photoboard but subsequently fails to identify the same person from a very similar photograph, the trial judge must clearly and specifically direct the jury on the significance of that failure as a matter undermining the reliability of the positive identification, dealing separately with each accused. A general or unclear direction on 'negative identification' will not suffice. Additionally, where the prosecutor submits that the complainant had no motive to fabricate, a Palmer direction must be given, particularly where credibility is in issue and corroborative evidence is weak.
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