An indictment alleging a false statement using the words 'it was stated' is not confined to an express statement but extends to a statement having that effect or conveying that impression, consistent with cl 6(12) of Sch 1 of the Criminal Procedure Act 2004 (WA). Where multiple co-accused make similar false statements omitting the same information at the same time, the similarity of content and timing is admissible against each to prove deliberate falsity through an inference of agreement to conceal the truth, even where conspiracy is not charged. Such statements are not relied upon for the truth of their contents and the hearsay exclusion does not apply.
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