R v Lbi

[2025] QCA 104

Queensland Court of Appeal

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Interrogate

Catchwords

1. Criminal Law
2. › Appeal and new trial
3. › Miscarriage of justice
4. › Misdirection or non-direction
5. › Non-direction
6. › Whether [name withheld] direction on consciousness of guilt required where trial judge ruled statements were not admissions
7. › Whether directions given were adequate
1. Criminal Law
2. › Evidence
3. › Post-offence conduct
4. › Text messages between accused and complainant
5. › Whether statements capable of amounting to admissions by conduct
6. › Whether consciousness of guilt direction necessary
7. › Edwards v The Queen (1992) 173 CLR 653

Quick Take

An [name withheld] direction on consciousness of guilt is not required where the trial judge has ruled that the accused's post-offence statements are not admissions and the prosecution does not invite the jury to use them as evidence of consciousness of guilt, even where the statements are arguably capable of being understood as admissions.

Case Details

Citation[2025] QCA 104

CourtQCA

JurisdictionQueensland

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Relies on1

2022R v WBSQCA 180
Edwards v RHCA 19

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