Where drugs are found at a safe house rather than the accused's residence, the risk that a jury will equate knowledge with possession is materially reduced, and GNN-type directions distinguishing knowledge from control or dominion may not be required provided the trial judge clearly and repeatedly identifies the three components of possession. Propensity evidence of prior drug warehousing convictions involving the same type of drug has significant probative value in rebutting a defence of innocent association with premises used to store drugs.
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