A direction to approach a child complainant's evidence with care and to scrutinise it carefully is not deficient merely because the trial judge did not relate the warning to specific circumstances of the case, where no particular circumstances comparable with those in Robinson v R are identified. Evidence of complaint to a doctor two days after the alleged offence is capable of constituting fresh complaint where the delay is explicable by the complainant's age, threats to remain silent, and fear of consequences.
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