S and M Carpets is wrong and not a key authority in 2024. Also burden is not the same as standard. Burden is who needs to prove the case. Standard is whether it is BoP or higher. In short, use the second para and ignore the Be aware box - it is oversimplifying the way the standard works on fraud. If really interested, although a different standard again (comfortable satisfaction) the City CAS case has some good discussion on the point - City did argue that comfortable satisfaction meant criminal standard. This was dismissed.