The preferred form of propensity warning — that the jury is not to reason that the accused is the kind of person who is likely to have committed the other offences charged — should be used in multi-complainant sexual offence trials where evidence is not cross-admissible, though other forms may be sufficient depending on the facts, precise language and context. A Palmer direction is not required where the prosecution merely invites the jury to assess the inherent plausibility of the evidence without raising the issue of motive to lie, nor where defence counsel raises motive for their own forensic purposes.
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