The requirement to direct a jury that lies may be explicable by consciousness of guilt of a lesser offence (such as manslaughter rather than murder) does not apply in all cases. Where neither prosecution nor defence contends for manslaughter, the defendant's own admissions convey that a murder was committed, and the trial judge's directions adequately convey that lies cannot be used unless told because of consciousness of guilt of murder, the absence of an express reference to manslaughter does not occasion a miscarriage of justice. Similarly, an Edwards direction is not required for post-offence conduct (such as a false alibi document) where defence counsel's forensic strategy was to attribute the document to another person and seeking such a direction would have been contrary to the defence case.
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