The bolster rule does not prevent an accused from explaining in examination-in-chief an inconsistency between a prior statement and trial evidence where the explanation addresses a central plank of the Crown case. A prosecutor who fails to put inconsistencies between a police interview and trial evidence to the accused in cross-examination, but then relies on those inconsistencies as the central plank of the closing address, breaches the rule in Browne v Dunn and causes a miscarriage of justice. No element of fraud under s 403C(1)(d) of the Criminal Code (Qld) requires proof of detriment.
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