R v Apostilides (1984) 154 CLR 563 - If witness is demonstrably non-truthful, there is no obligation to call them as a witness. - E.g., accused's friend saying he would give evidence no matter what to get his friend off. - The Prosecution have the responsibility to call people as witnesses. - We must call them unless there is a good reason not to do so. - You must call all evidence even if its favourable or unfavourable. ## Reasons not to call witnesses - Unreliable, untrustworthy or otherwise incapable of belief - Must be more than a mere suspicion of unreliability. - Contradictory statements are not enough. - Unnecessarily repetitious, in light of the number of witnesses available to prove certain matters - Relates to an issue where defence bears the onus of proof