R v PBG

A [name withheld]-type corroboration direction is not required for confessional statements made to a family member outside custodial circumstances, as the special circumstances justifying such a direction (the position of disadvantage of an accused making a confession in custody) are not present. A [name withheld] direction need not specifically address the prejudice of delay in obtaining phone records where the dispute concerns the content of phone calls rather than whether the calls occurred. A motive to lie direction is not required for a confession witness (as distinct from a complainant) where no issue arises as to the witness's motive to make and maintain a false allegation that creates a potential for illogical reasoning by the jury.