A trial judge's uncharged acts direction must include all three components identified in R v Grech: (1) the relationship direction (evidence admitted to establish the relationship as context), (2) the anti-substitution direction (uncharged acts cannot substitute for proof of charged offences), and (3) the propensity direction (jury must not reason that because the accused engaged in sexual conduct on other occasions, he was the kind of person likely to have done so on the occasions charged). Failure to give the propensity component, even where the anti-substitution direction is given, constitutes a misdirection warranting the quashing of convictions.
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