When relationship evidence of uncharged sexual misconduct is admitted in a child sexual assault trial, the trial judge must: (1) explain the limited purpose for which the evidence was admitted; (2) warn the jury against using the evidence as proof of tendency or propensity; and (3) warn against substituting the evidence of uncharged acts for the specific allegations constituting the charges. The warning against substitution is particularly important where the uncharged acts evidence is detailed and specific. The Crown bears a particular duty to ensure adequate directions are given when it adduces such evidence.
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