Evidence of a complainant's distressed condition at the time of complaint may be admitted as corroborative even where the last charged offence occurred approximately two months earlier. The law on admissibility of uncharged sexual conduct as relationship evidence remains as stated in R v Beserick and R v AH, the reasoning of Gaudron J in Gipp v The Queen not reflecting the present law. Pre-text telephone conversations and emails are admissible as relationship evidence where their probative value is not outweighed by the danger of unfair prejudice under s 137 of the Evidence Act 1995.
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