An Edwards direction must be given where there is a perceptible risk the jury will treat post-offence conduct as evidence of consciousness of guilt, even where the prosecution disavows reliance on consciousness of guilt reasoning. The rule in Browne v Dunn requires the prosecutor to put to the accused all adverse inferences intended to be drawn from the accused's conduct, and the trial judge must direct the jury on the prosecutor's failure to do so. Evidence of a witness's suspicion as to the accused's state of mind, where the witness does not attribute a statement to the accused, is inadmissible.
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