Here it is alleged by the Crown, and must be proved by the Crown beyond reasonable doubt, that [the accused] intended to defraud [the victim] by … [specify the nature of the fraudulent conduct].

To “defraud” is to intentionally use dishonest means to deprive another person of their property, or to imperil their rights or interests. It involves the intentional creation of a situation by one person to use dishonest means to deprive another person of money or property, or to imperil another person’s rights or interests, [here identify the knowledge, belief or intent that is said to render the relevant conduct dishonest] knowing that they have no right to deprive that person of money or property, or imperil that person’s rights or interests. The “dishonest” means which the Crown says [the accused] used here were … [give details of the evidence].

The Crown must establish beyond reasonable doubt that the accused had that knowledge, belief or intent and, if so, on that account, the relevant conduct was dishonest. In determining whether the conduct of the accused was dishonest, the standard which you apply is that of ordinary decent people.

[Where appropriate

There may be an intent to defraud even though the defrauder does not intend to benefit [himself/herself]. The essence of the meaning of the word “defraud” is “detriment” or “damage” or “loss” to the person defrauded by the use of dishonest means, not an advantage to the defrauder.]

For present purposes, the words “intent” and “intention” have the same meaning. They are very familiar words and in this legal context they carry their ordinary meaning. Intention may be inferred or deduced from the circumstances in which … [specify the alleged fraudulent activity] is alleged to have occurred, and from the conduct of [the accused] person before, at the time of, or after [he/she] did the act alleged to be fraudulent, namely … [specify the alleged fraud]. Whatever a person says about their intention may be looked at for the purpose of finding out what in fact that intention was at the relevant time … [specify the time]. In some cases, a person’s acts or words may themselves provide the most convincing evidence of their intention.

Where a specific result is the obvious and inevitable consequence of a person’s act, and where they deliberately do that act, you may readily conclude that they did that act with the intention of achieving that specific result. In the present case that is … [set out the alleged fraud].

You must remember that you are considering the intention of [the accused], not what your intention, or the intention of the ordinary person, or some imaginary person, might have been had you (or they) been in [the accused’s] position.

I emphasise that what the Crown has to prove is the dishonest intent of [the accused] — not of any other person. Further, the intended means by which the purpose was to be achieved must be dishonest.