A complaint made three to five years after the alleged sexual offence cannot qualify as a recent complaint. Evidence of an act on which the accused was acquitted at the same trial is not capable of corroborating the complainant's testimony on other charged offences. In cases where the complainant's evidence on one count raises serious doubts about veracity, a Markuleski direction should be given instructing the jury that a reasonable doubt on any count should be taken into account in assessing the complainant's evidence generally; without such a direction, differing verdicts may be fatally inconsistent.
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