R v PLK

Where the Crown case depends entirely on a complainant's uncorroborated evidence in a sexual offence trial, and the prosecutor addresses the jury at length seeking to demolish a specific motive to lie advanced by the defence, the trial judge must direct the jury that rejection of the suggested motive does not mean the complainant is necessarily telling the truth and that the Crown must still prove its case. The 'bolster rule' (R v Turner) is limited to admissibility and does not prevent a trial judge from directing the jury that properly admitted evidence of uncharged sexual acts renders the complainant's evidence of charged acts more credible. A propensity warning is not required in respect of charged acts where the jury has been directed to consider each count separately. The question whether a Palmer direction is mandatory in every case where specific motives to lie are raised was left open, with the majority holding it was required on the facts of this case and the dissent holding it was not mandatory.