Where uncharged acts evidence is admitted to show the relationship between the accused and complainant in sexual offence cases, the trial judge must give a specific direction warning the jury not to use that evidence as propensity reasoning. The need for such a direction is heightened where the uncharged acts extend to non-sexual violence and to victims other than the complainant. Failure to give the direction constitutes an error of law that cannot be cured by the proviso where the accused has been deprived of a chance of acquittal.
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