Statements by a very young child describing sexual acts, accompanied by simulated sexual behaviour and reference to a 'silly secret', are capable of constituting a 'complaint' for the purposes of the recent complaint doctrine, even where the child does not express grievance or understand the wrongfulness of the conduct. Where a child complains of a course of sexual conduct and the complaint is recent as to some acts, the complaint evidence may be admissible in relation to all counts. The age and immaturity of a child complainant, and the child's lack of understanding that the conduct was wrong, are relevant to whether a complaint was made at the first reasonable opportunity.
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