Evidence of lies and post-offence conduct, including concealment of a body, is properly admissible as going to consciousness of guilt of unlawful killing generally, and need not be confined to consciousness of guilt of the specific offence charged as opposed to a lesser included offence. A murder conviction will be unsafe and unsatisfactory where the cause of death cannot be ascertained, the pathologist cannot exclude natural causes or drug overdose, and the evidence is insufficient to establish murderous intent beyond reasonable doubt, even where the accused admits involvement in a physical struggle preceding death.
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