A prosecution submission that if the jury finds no concoction, the only possibilities are that complainants are lying 'for some unknown reason for which there is no evidence' or telling the truth, is an improper reversal of the onus of proof. However, such an error may be adequately corrected by firm jury directions that the accused bears no onus to prove any reason or motive for a witness's evidence and that the burden remains on the prosecution. The failure of defence counsel to seek a redirection after the summing up is relevant to whether the directions were adequate.
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