The reasonableness element of s 24 of the Criminal Code (WA) is a mixed subjective-objective test: the accused's actual belief must be reasonable judged by reference to the accused's personal attributes affecting perception (age, gender, ethnicity, disabilities), but not by the wholly objective hypothetical reasonable person standard. Self-induced intoxication cannot support reasonableness, and personal values (cultural, religious or otherwise) are excluded from the assessment. Daniels v The Queen is wrong insofar as it approved the wholly objective test. Trial judges should not use the standard formula referring to the ordinary person and should instead tailor directions to the facts of each case. Lies told by an accused to a complainant are capable of being Edwards lies where the falsity of the lie is established independently of the complainant's evidence of the offence (e.g., by the accused's own admissions at trial).
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