Evidence of an accused's animosity towards the victim, including bizarre behaviour and self-harm during pregnancy, is not propensity evidence requiring a BRS direction but is directly admissible as evidence probative of intent and motive for murder. Incomplete directions on s 23(1)(b) of the Criminal Code 1899 (Qld) that favour the accused by omitting that accident is also excluded by the accused's own intention or foresight do not cause a miscarriage of justice. Directions on accident under s 23 in murder trials need not be given as a matter of course but only where the evidence fairly raises the issue.
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