Where a prosecutor submits to the jury that an accused's lie to police was an effort to 'distance himself' from the offence, this constitutes reliance on the lie as evidence of consciousness of guilt, requiring an Edwards direction rather than a Zoneff direction. A Zoneff direction is inadequate where the prosecution has invited the jury to treat the lie as an implied admission of guilt, even if the trial judge initially ruled the lie went only to credit. In a finely balanced case, the failure to give the correct direction will constitute a miscarriage of justice.
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