A post-offence lie by an accused that is probative of a fact in issue relevant to multiple charges arising from the same set of facts may properly be left to the jury as an Edwards lie in relation to each charge; it need not be allocable to a particular charge. It is sufficient if the lie reveals knowledge of some aspect of the offence charged, not all elements. Where a lie relates generally to multiple illicit items found together, a trial judge's direction that the lie 'could only operate at a general level' is adequate provided the judge also directs the jury that consciousness of guilt must be relevant to the specific charge being considered.
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