A Crown prosecutor's comment that a witness has 'no axe to grind' with the accused is not equivalent to the prohibited question 'Why would he/she lie?' where the comment is directed to the witness's neutrality and impartiality rather than to the absence of a motive to fabricate. The expression 'axe to grind' has a wider connotation than dishonesty and, when used in the context of assessing witness reliability, does not generally give rise to a shift in the onus of proof. The case also provides a comprehensive restatement of the circumstances in which the prohibited question may occasion a miscarriage of justice.
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