There is no rule of law or practice in South Australia requiring a trial judge to direct the jury that a failure to be satisfied about the complainant's evidence on one count should be carried into deliberations on other counts; whether such a direction is required depends on the circumstances of the particular case. The consistency which evidence of recent complaint primarily goes to prove is consistency of conduct — raising the hue and cry — rather than a precise coincidence of accounts. Touchings immediately prior to and forming part of a charged incident are not 'uncharged acts' requiring a propensity warning.
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