Where the prosecution adduces evidence of post-offence conduct for a limited purpose (such as connecting the accused to the scene) but then uses that evidence in cross-examination or address to insinuate consciousness of guilt, the trial judge must inquire of the prosecution as to the use it seeks to make of the evidence and direct the jury that the evidence cannot be used as evidence of guilt. The appropriate direction in such circumstances is not a full Edwards direction but a limiting direction confining the evidence to its permissible purpose. Failure to give such a direction where the prosecution has insinuated guilt from the conduct will constitute a miscarriage of justice.
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