The case provides a comprehensive statement of the principles governing the admissibility of tendency and coincidence evidence in sexual offence cases involving multiple complainants, including the threshold for concoction and contamination. It clarifies that contamination must go to the substance of the evidence to affect admissibility, and that the distinction between tendency and coincidence reasoning identified in R v DCC does not apply where tendency reasoning is permissible under the Evidence Act 1995. On sentencing, the case confirms that historical sexual offences must be assessed against the maximum penalty and sentencing practices current at the time of offending, and that individual sentences must reflect the objective seriousness of each count before the totality principle is applied.
The full text is available to signed-in members, including the 56 later cases that cite this judgment.
14 of the 56 citing cases carry a classified treatment. How each court treated it is available to signed-in members.