The falsity of a statement said to constitute a lie evidencing consciousness of guilt may be proved by circumstantial evidence; there is no requirement that the falsity be demonstrated by 'immediate pieces of independent evidence' in a 'straightforward and simple manner'. Where the circumstantial case to prove the lie is not co-extensive with the circumstantial case to prove the offence, the reasoning is not circular. Each repetition of a lie must be treated as a separate asserted lie with separate directions as to alternative explanations.
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