Where a prosecutor remarks in closing address on the absence of an apparent motive for a complainant to lie, the trial judge must expressly direct the jury that the absence of evidence of motive is irrelevant to the assessment of the complainant's credibility and is entirely neutral. A direction that merely reminds the jury of the onus of proof and that the defence has no obligation to prove a motive is insufficient to neutralise the prejudice. Directions that risk inviting the jury to draw inferences about motive compound rather than cure the problem.
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