Whether a specific warning about the limitations of distress evidence is required depends on the circumstances of the case, including how the evidence was put by the parties and the directions given about complaint evidence generally. Where distress evidence is advanced as part of complaint evidence going to credibility (not as independent corroboration), a direction treating distress evidence in the same way as complaint evidence may be sufficient.
The full text is available to signed-in members, including the 4 later cases that cite this judgment.
2 of the 4 citing cases carry a classified treatment. How each court treated it is available to signed-in members.