Evidence of complaint not made at the earliest reasonable opportunity may be admitted where defence counsel tactically allows it in and uses it as part of the defence case; the accused is bound by that forensic decision. The three minimum requirements for jury directions on relationship evidence identified in Cook v The Queen are confirmed as the applicable standard. The Longman warning need not incorporate the specific observations of McHugh J regarding fallibility of recollection where the delay is substantially shorter than the 20-year period in Longman.
The full text is available to signed-in members, including the 7 later cases that cite this judgment.
1 of the 7 citing cases carry a classified treatment. How each court treated it is available to signed-in members.