The majority held that post-offence conduct in the form of financial payments to a complainant does not carry the same inherent dangers as lies evidence and does not require an Edwards-type direction. Such evidence is merely circumstantial evidence to be weighed with all other evidence, and the jury does not need to be satisfied beyond reasonable doubt that the conduct evinces consciousness of guilt before using it. However, the strong dissent of White J indicates that where the prosecution relies heavily on such conduct as an implied admission of guilt, the question of whether an Edwards-type direction is required remains contested.
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