Where sexual offences against multiple complainants are joined in one indictment, the significant probative value of the evidence of each complainant in relation to the counts involving the other must be assessed in the context of the totality of the circumstances, including familial relationships, temporal proximity, common location, and specific connections between the accused's conduct towards each complainant. The dissimilarity in the types of sexual conduct and the gender and age of the complainants does not necessarily negate significant probative value where there are strong connecting factors. However, [name withheld]'s dissent cautions that s 31A cannot be employed by a process of over-generalisation, and that the mere fact that an accused had a sexual interest in one child does not make that evidence probative of offences against another child where the offences are not otherwise related.
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