In circumstantial cases, an applicant cannot succeed on an unsafe and unsatisfactory ground by disaggregating and individually explaining away each strand of circumstantial evidence; the evidence must be assessed collectively as required by R v Hillier. A Zoneff direction limiting the use of an accused's lies to credibility assessment (rather than as implied admissions of guilt) is the appropriate direction where the evidence is insufficient to establish the lies as implied admissions under Edwards. Post-mortem mutilation of a victim remains a significant aggravating factor in sentencing for murder.
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