Where the Crown does not contend that an accused's lies are evidence of consciousness of guilt, a Zoneff direction is ordinarily sufficient, and an Edwards direction is unnecessary unless the judge apprehends a real danger the jury may apply impermissible reasoning. Even where an Edwards direction would have been preferable, the conviction will be upheld if the applicant cannot demonstrate a reasonable possibility that the failure to give the direction may have affected the verdict. Sentences for threat counts should not be cumulated with sentences for offences that were effected by means of those threats.
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