The case confirms that the Edwards v R framework governs the use of lies as consciousness of guilt, superseding the earlier formulations in R v Sutton and R v Heyde. It was open to the jury to accept part of a witness's evidence (that the complainant and accused were in the shed) while rejecting other parts (the details of what occurred), for the purpose of independently establishing a lie. On sentencing for s 66A offences, the Court was divided on whether a sentence of 12 years (NPP 9 years) for an isolated offence of enforced fellatio on a five-year-old was manifestly excessive, with the majority holding it was within range.
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