An accused's explanation for possession of recently stolen property, where the explanation is improbable and the corroborating witness is inconsistent, is capable of being found by a jury to be a lie demonstrating consciousness of guilt. A consciousness of guilt direction based on a lie about how stolen property was obtained relates to a material issue and does not constitute impermissible bootstraps reasoning, because the jury does not need to assume the accused committed the offence in order to assess whether the explanation is false.
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