Where relationship or context evidence of uncharged sexual acts is admitted in a sexual assault trial, the trial judge must identify the specific issue which justifies the admission of the evidence and direct the jury that they cannot use the evidence to reason towards the guilt of the accused. A generalised direction that the evidence shows the 'true nature of the relationship' without identifying the specific issue it addresses invites impermissible propensity reasoning. The use of the word 'directly' in a prohibition against using the evidence to reason towards guilt implies the evidence may be used 'indirectly' for that purpose and is inadequate.
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