Where the Crown Prosecutor's address invites the jury to conclude that lies told by the accused evidence a consciousness of guilt, the trial judge must give a Zoneff-style direction in the clearest terms warning the jury not to use any lie as evidence of guilt, even if no Edwards direction is sought and even if the judge has not been asked for such a direction after the summing up. Failure to do so will cause the trial to miscarry.
The full text is available to signed-in members, including the 2 later cases that cite this judgment.