A direction on a complainant's motive to fabricate is necessary only if there is a risk the jury might reason from rejection of the suggested motive to a conclusion that no motive exists, or that the accused's failure to identify a plausible motive is itself probative. The mere absence of evidence of motive does not prove the non-existence of motive, and a complainant's credibility is generally neither enhanced nor reduced by the jury's rejection of a defence-suggested motive. Where the motive issue was a minor part of the defence case and was not pursued by the prosecution, the absence of a direction will not constitute a miscarriage of justice.
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