A Burns direction requiring the jury to be satisfied beyond reasonable doubt that a confession or admission was truthful is only required where the evidence amounts to a full confession, or an admission of a fact that must be proved to the criminal standard, or an indispensable link in the chain of evidence necessary to establish guilt. Where an ambiguous text message is relied on as only one piece of evidence providing general support for the prosecution case, and is not a 'major plank' in that case, no such direction is required. The trial judge retains a duty to ensure trial fairness by giving adequate directions about impermissible uses of evidence, even where defence counsel has made a forensic decision not to object to that evidence.
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