A trial judge's Edwards direction on lies as consciousness of guilt is adequate where it identifies the lies, requires the jury to be satisfied they were deliberate, requires consideration of alternative explanations, and requires separate consideration of each count — even where the judge reminds the jury of defence counsel's submissions as to alternative explanations rather than independently hypothesising alternatives. In complicity cases, a secondary offender's understanding of the principal offender's intentions is a relevant fact bearing on the scope of the common purpose and the secondary offender's liability. The question left open in Le Broc as to the elements of intent necessary for aiding and abetting a reckless act remains unresolved.
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