A false accusation by an accused that a named third party committed the offence is capable of being an Edwards lie evidencing consciousness of guilt, provided the falsity of the accusation can be established by evidence independent of proof of the accused's guilt. The falsity need not be established by the same evidence relied on to prove the prosecution case. A minimum non-parole period of 18 years for a domestic violence murder involving sustained violence, no weapon, no intention to kill, and limited mitigating factors is within the sentencing range.
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