An anti-propensity direction is not required as a matter of law for general, unparticularised evidence of continuity of a sexual relationship; such a direction is only necessary where the evidence descends to particular uncharged incidents capable of being used as propensity evidence or where there is a risk of conviction on the basis that at least some illegal conduct has occurred. The Queensland test for admissibility of complaint evidence in R v W [1996] 1 Qd R 573 may no longer be reliable following the High Court's endorsement of the 'earliest reasonable opportunity' test in Suresh v The Queen [1998] HCA 23.
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