A Crown Prosecutor's submission that a victim had good reason not to lie (because a false identification would leave the real attacker free to harm the victim again) is not the impermissible 'why would the victim lie?' question identified in Palmer v The Queen. The distinction is between asking the jury to speculate about motives to lie (impermissible) and submitting that the circumstances provide a positive reason why the witness told the truth (permissible). Where defence counsel deliberately declines identification directions after the trial judge raises the issue, leave to appeal on that ground will be refused.
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