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In this case, [identify how issue of whether the witness has a motive to lie has been raised]. The [suggestion/implication] is that NOW has a motive to give false evidence.
If you accept that NOW [identify relevant motive], or might have [identify relevant motive], then you will need to consider whether that affected the evidence s/he gave.
On the other hand, if you reject the idea that NOW [identify relevant motive], then you will ignore that argument when you are deciding what weight to give his/her evidence.
Remember, it is for the prosecution to prove, beyond reasonable doubt, that the accused is guilty. You can only convict NOA of [insert offence] if, on the basis of all the evidence, you are satisfied of his/her guilt beyond reasonable doubt.
The accused does not have to prove that NOW had a reason for giving false evidence.
[Refer to relevant evidence and arguments of the parties]
Last updated: 2 October 2017