Where a prosecution case relies on multiple categories of lies told by an accused in different circumstances and for different purposes, a generic lies direction is insufficient. Each category of lie must be specifically identified with tailored directions as to its permissible and impermissible uses. Post-death lies that seek to lay a false trail about the cause and circumstances of death require a full Edwards direction. The proviso will not save a conviction where inadequate lies directions may have affected the jury's assessment of the defence case, even where the prosecution case is very strong.
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