[The accused] is charged with making a false instrument with the intention that [he/she/other [specify]] would use that instrument to induce [other person] to accept the instrument as genuine, and because of that acceptance, [to do/not to do] an act to that person’s prejudice … [specify].

In order to establish its case against [the accused], the Crown must prove beyond reasonable doubt, firstly, that [he/she] made an instrument. An instrument includes a document … [credit card, disc, tape, soundtrack etc as indicated in s 299(1) — specify the instrument relied on by the Crown].

Making a false instrument is proved where the instrument purports to … [specify the circumstances alleged by the Crown in paras (a) to (h) under s 299(2)]. If you find beyond reasonable doubt that the instrument in question purports to have been [made/altered] as alleged by the prosecution, and that this was done by [the accused], then the Crown will have established that [the accused] [made/altered] that instrument. The word “purports” is used in the sense of “pretends” — so that the Crown must show that the document is not what it appears to be, in that it appears to have been [made/altered] by [name] when it was not [made/altered] by [name] … [or as the case may be according to s 299(2) relied on by the Crown].

The Crown must next prove that in [making/altering] the false instrument, [the accused] did so with the intention that [he/she/other [specify]] induced [name of person], not being the [accused/person intended by the accused to use the instrument] to accept the instrument as genuine, that is to say, as what it purports or pretends to be, and because of that acceptance, to do or refrain from doing something to the prejudice of [person intended to be so induced], in that [name of person] [did/did not do] an act which if [done/not done] would be to [his/her] prejudice in that … [specify the particulars of prejudice relied upon by the Crown within s 305]. If you find that to have been [the accused’s] intention beyond reasonable doubt, then the Crown will have established that [the accused] intended prejudice to [name of person].

It is not necessary that the Crown prove that the person intended to be induced was induced or did [do/ not do] the act to [his/her] prejudice, but it is necessary for the Crown to prove beyond reasonable doubt that it was within [the accused’s] intention at the time of making the document that [name of person] should be so induced.

“Intent” and “intention” are very familiar words and in this context — they have their ordinary everyday meaning.

Intention may be inferred or deduced from the surrounding circumstances in which the instrument was [made/altered], including the nature of the document itself and [the accused’s] conduct before and at the time of, or even after [he/she] [made/altered] it … [deal with other relevant matters relied on by the Crown as going to intention, such as the relationship between the parties. Deal with any evidence and/or submissions for the accused on this issue].

[The accused] is charged with using an instrument which was false and which [he/she] knew to be false, with the intention of inducing another person to accept the instrument as genuine and because of that to [do/not do] some act to [that other person’s/another’s] prejudice … [specify if disclosed].

In order to establish its case against [the accused], the Crown must prove beyond reasonable doubt firstly that [he/she] used an instrument. An instrument means a document … [includes a credit card, disc, tape, soundtrack etc as defined in s 299(1) — specify the instrument relied on by the Crown]. The Crown alleges that [the accused] used the instrument by … [specify the Crown’s allegations and evidence in support and any evidence relied on by the accused on this issue, together with opposing submissions].

An instrument is false if it purports to … [specify the circumstances alleged by the Crown in paras (a)–(h) under s 299(2) if in issue and deal with any opposing evidence and/or submissions]. If you find beyond reasonable doubt that this instrument here in question purports to … [as alleged by the prosecution under s 299(2), specify], and that [the accused] used the instrument as alleged, then the Crown will have established that [he/she] used a false instrument. The word “purports” is used in the sense of “pretends”, so that the Crown must show that the instrument is not what it appears to be in that it appears to have been … [specify the particulars of falsity relied upon by the Crown within s 299(2)] when it was not.

The Crown must also establish beyond reasonable doubt that at the time when [he/she] used the false instrument, [he/she] knew it to be false. Knowledge is a state of mind. If it is to be shown to have existed generally, it must be inferred or deduced from the relevant circumstances existing before, at the time of or even after the use by [the accused] of the instrument. The relevant circumstances include the nature of the instrument itself … [deal with evidence and submissions of both the Crown and the accused on knowledge, if it is in issue].

In addition to proving that [he/she] knew it to be false, the Crown must also establish beyond reasonable doubt that [he/she] used the instrument with the intention that [another person] should be induced to accept the instrument as genuine, that is to say, as what it purports to be, and because of that acceptance, to [do/not do] something to the prejudice of the person who was so induced. A person will be prejudiced if, assuming the act had been [done/not done], it would … [specify the particulars of prejudice relied upon by the Crown within s 305].

If you find that to have been [the accused’s] intention beyond reasonable doubt, then the Crown will have established that [the accused] intended prejudice to [other person].

It is not necessary that [other person] be in fact induced to [do/not do] an act, nor that [he/she] in fact [did/did not] do the act, but it is necessary that the Crown establish beyond reasonable doubt that it was the intention of [the accused] that [other person] be induced to [do/not do] an act to [his/her] prejudice, as alleged by the Crown.

Like knowledge, intention is a matter to be inferred or deduced from the relevant circumstances. These include … [deal with the evidence relied upon by the Crown and any evidence to the contrary relied upon by the accused on the issue of intention and also the opposing submissions on this issue, if it arises].