Where a complainant's evidence linking offences to specific events is incontrovertibly contradicted by objective evidence, and the trial judge directs the jury to return the same verdict on all counts without directing that each count must relate to one specified event, there is a risk of conviction for uncharged matters constituting a miscarriage of justice. A trial judge's suggestion that timing is immaterial where the defence is a denial may impermissibly shift the onus of proof.
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