Where the prosecution characterises an accused's claims of memory lapse in a record of interview as deliberate lies, and alleges concoction of evidence with a witness, an Edwards direction is required even if the prosecution disavows reliance on consciousness of guilt, because the criterion is the way the jury might use the evidence. A Zoneff direction may not suffice where the prosecution's address as a whole creates a real danger of impermissible reasoning. Additionally, where an accused claims intoxication and the evidence supports that claim, a specific direction on intoxication as it relates to belief in consent is required.
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