Evidence of a complaint of a sexual offence is admissible through the complainant's own testimony even where the person to whom the complaint was made has died and cannot be called; independent confirmation is not required. Where evidence is cross-admissible between counts involving different complainants due to underlying unity of conduct, severance of the presentment serves no purpose and may properly be refused. An unauthorised communication between a tipstaff and jury on the question of unanimity is not a fundamental irregularity incapable of correction by judicial direction, provided it is promptly addressed in open court.
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