In sexual offence cases involving multiple complainants, the common pattern of grooming behaviour — fostering relationships with teenage boys through employment, supply of alcohol and drugs, and efforts to loosen sexual inhibitions — may constitute tendency evidence of sufficient probative value to be admitted under s 101 of the Evidence Act 1995, even where the specific sexual acts and circumstances differ between complainants. Trial judges directing on confirmatory evidence should avoid invoking the technical common law concept of corroboration. On sentence, a Pearce complaint about an individual count within an accumulated total will not succeed unless the aggregate sentence is shown to be excessive.
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