Evidence of sexual offending against one complainant involving broadly similar circumstances (such as incidents in showers or in situations where discovery was possible) does not, without more, possess sufficient similarity to be admissible as similar fact evidence to prove offences against another complainant. Where multiple complainants are involved and similar fact evidence is not properly admissible, the 'two complainants' direction must instruct the jury not to supplement evidence on counts involving one complainant by looking at evidence about the other. Edwards directions on consciousness of guilt lies must be restricted to the complainant in respect of whom the lie is probative and must not be used where proof of the lie depends on acceptance of the very evidence the lie is said to corroborate.
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