Consciousness of guilt reasoning requires the Crown to submit that the accused acted because they appreciated their guilt and wished to conceal it; submissions that the accused's behaviour was inconsistent with their version of events are not consciousness of guilt reasoning and do not require an Edwards direction. A full Liberato direction is inapposite where the Crown relies on the accused's own admissions in evidence. Appellate courts should not attempt to parse jury verdicts to identify the reasoning process underpinning them, even where there are acquittals on some counts and convictions on others.
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