The word 'dishonest' in s 191(1) of the Crimes Act 1958 (Vic) is assessed by the [name withheld] objective test: whether the conduct was dishonest by the standards of ordinary, decent people. There is no requirement to prove the accused subjectively appreciated their conduct was dishonest. The mental element for 'dishonest concealment' requires proof that the accused knew the material facts, appreciated their materiality, and deliberately withheld them. Bond v The Queen, which adopted the [name withheld] subjective test for an equivalent provision, is no longer of assistance.
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