Where the Crown relies on evidence of flight from police as one strand in a combined circumstantial case (not as independent proof of guilt), the trial judge is not required to direct the jury that the fact of flight must be proved beyond reasonable doubt before it can be used. The conventional circumstantial evidence direction — that guilt must be the only reasonable inference from the established circumstances — is sufficient. The distinction between 'links in a chain' and 'strands in a cable' cases remains difficult to apply in practice, and the Court acknowledged this remains an unresolved area.
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