Evidence of post-offence armed robbery and flight is admissible as evidence of consciousness of guilt of murder where the robbery was committed to fund the accused's escape from the consequences of the killing, even though it reveals another criminal offence. The probative value of such evidence is high where the accused's statements during the robbery constitute admissions. However, where the accused admits the killing but claims self-defence or provocation, consciousness of guilt directions must be carefully tailored — there is a question (not resolved by the majority) whether standard directions adequately address the distinction between consciousness of guilt of murder and consciousness of guilt of other offences. Evidence of possession of weapons not shown to have been used in the offence should be excluded under s 137 as potentially suggesting propensity.
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