A Liberato direction is not required where defence evidence does not directly contradict the complainant's evidence or provide an alternative version of events, but rather challenges the complainant's credibility. In such cases, the rejection of the defence evidence logically depends on acceptance of the complainant's credibility, which is the central issue for the jury, and there is no danger of the jury accepting the complainant's version to a standard below proof beyond reasonable doubt. The adequacy of directions must be assessed by reference to the summing up as a whole.
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