R v L

The Court of Appeal was divided on whether the conviction was unsafe. [name withheld] (in dissent) held that the trial judge's directions on corroboration through evidence of distress were effectively circular and could not have assisted the Crown, but that the conviction was nonetheless safe given the complainant's evidence, medical evidence of hymenal rupture, and the jury's assessment of credibility after extensive cross-examination. The majority allowed the appeal on the basis that the distressed condition evidence eight months after the alleged offence lacked sufficient causal connection and was wrongly admitted as capable of corroboration. The case illustrates the tension between appellate review of jury verdicts and deference to the jury's assessment of witness credibility, particularly child complainants in sexual offence cases.