Where the Crown relies on post-offence conduct such as disposal of a mobile phone as corroborative of a complainant's account, an Edwards-type direction on consciousness of guilt reasoning is required, particularly where the jury would otherwise be led to treat the disposal as almost indisputable evidence of guilt. However, the absence of such a direction will not necessarily result in a substantial miscarriage of justice where the remaining evidence is sufficiently strong to prove guilt beyond reasonable doubt.
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