In child sexual abuse cases, evidence of uncharged incidents forming part of the relationship between the accused and complainant is admissible to assess the complainant's credibility and the nature of the relationship, but a trial judge must not direct the jury that they may reason directly from such an incident to a conclusion that the charged offences occurred. Where the case is one of oath against oath, a misdirection on this point in respect of the only independently supported aspect of the complainant's evidence has such potential to deprive the accused of a fair trial that the conviction must be quashed. Evidence that other uncharged sexual acts of the same kind occurred is admissible to explain why a complainant cannot recall precise details, provided appropriate warnings are given.
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