A [name withheld] direction is not required merely because it is suggested that something a defendant said should be rejected as untrue; it is only required where there is a real risk of the jury inferring guilt from lies relevant only to credit. In sexual offence cases, evidence of a defendant's conduct additional to charged offending falls into three categories — uncharged sex offending, conduct exhibiting sexual interest, and contextual relationship evidence — and the need for a propensity warning depends on the real risk of misuse, not the mere presence of additional conduct evidence. Defence counsel's failure to seek a direction at trial is cogent evidence that the direction was not required in the context of the trial.
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