A lies direction under Zoneff v The Queen is not required where the prosecution does not seek to establish that the accused lied and the jury would not reason from the evidence that a lie was told. A direction that each indispensable fact must be proved beyond reasonable doubt is not required where the Crown's circumstantial case consists of strands in a cable rather than links in a chain. An appellant's claim that defence counsel's failure to call evidence caused a miscarriage of justice will fail where the appellant made a considered decision not to give evidence after proper advice and the decision was capable of producing a significant forensic advantage.
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