The appellant, convicted of second-degree murder, appealed his conviction, alleging reversible misdirection in the jury instruction on after-the-fact conduct.
The appellant had dismembered and disposed of the victim's body after her death, which he claimed was due to an overdose, fearing police scrutiny.
The Court of Appeal found that the after-the-fact conduct evidence was relevant and admissible to infer unlawful causation of death and mens rea for murder.
The trial judge's instructions on drawing inferences from circumstantial evidence, including after-the-fact conduct, were deemed adequate.
The Court also found no reversible error in the absence of a specific "bad character" caution, given the direct connection of the conduct to the charge.
The appeal was dismissed.