A Zoneff-type direction on lies told by an accused is adequate to guard against the perceptible risk of jury misuse even where the prosecutor's cross-examination (but not closing address) could reasonably be understood as suggesting the lies were told out of consciousness of guilt. Where the prosecution's closing address, read as a whole, relies on lies only as going to credibility and not as evidence of guilt, an Edwards direction should not be given. Defence counsel's concession at sentencing that the appellant's offending was equal to a co-accused's precludes a challenge on appeal to a factual finding made against the co-accused and adopted against the appellant.
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