'Course of conduct' in s 21A of the Crimes Act 1958 (Vic) requires a pattern of conduct evidencing a continuity of purpose; the conduct must be either protracted or engaged in on more than one separate occasion. The Victorian provision, despite lacking the express 'two separate occasions' requirement found in Queensland, Northern Territory and South Australian legislation, still requires more than a single non-protracted occasion by virtue of the inherent meaning of 'course of conduct'. Where the prosecution relies on circumstantial evidence to establish multiple occasions of conduct, the criminal standard requires exclusion of reasonable hypotheses consistent with innocence.
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