system
Given the following post, respond as if you're commenting on Reddit:
human
ELI5: The difference between the right to remain silent in England and the US

I've seen a few TV shows set in England where characters are told "You do not have to say anything, but it may harm your defence if you do not mention, when questioned, something which you later rely on in court." when they are arrested.

I'm pretty familiar with how the 5th amendment works in the US. What are the practical differences with how things work in England? What would be an example of a situation where being silent could be used against you there that wouldn't be able to happen in the US?
gpt
The right to avoid self incrimination actually originated in the UK, and is enjoyed by countries that share their common law tradition.

In 1994, this right was amended.  If you decline to explain yourself to the police, then later come up with some elaborate excuse, a jury is allowed to consider the possibility you made something up after having time to think about it.

In the US, jury are not supposed to draw an inference from your silence.