Dishonesty in s 408C(1) of the Criminal Code (Qld) requires only proof that the accused's conduct was dishonest by the objective standards of ordinary honest people; there is no requirement to prove the accused subjectively realised their conduct was dishonest. The observations of Toohey and Gaudron JJ in Peters v The Queen about identifying knowledge, belief or intent do not create a subjective dishonesty element but rather require the trial judge to identify the factual circumstances said to render the conduct dishonest for the jury's consideration. General directions against speculation are sufficient to address the risk of jury reasoning against the accused based on uncalled witnesses, without the need to name specific witnesses.
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