Where uncharged sexual acts are admitted as relationship or propensity evidence under s 31A of the Evidence Act 1906 (WA), the trial judge is not required to direct the jury that the uncharged acts must be proved beyond reasonable doubt, provided the uncharged acts are not an indispensable link in a chain of reasoning towards guilt and the complainant gives direct evidence of the charged offences. No propensity warning is required for evidence admitted generally under s 31A. A total effective sentence of 14 years 6 months' imprisonment for prolonged intra-familial sexual abuse of a child over 10 years, continuing into adulthood, was upheld as within the proper exercise of the sentencing discretion.
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