Where multiple complainants give conflicting evidence about the same alleged occasion in a sexual offence prosecution, the bare 'first occasion' method of particularisation is insufficient; the Crown must provide a base narrative reconciling those accounts at least to the extent of encapsulating all counts charged. The 'first occasion' method should only be used as a last resort where it is not possible to particularise by other distinguishing features, and is unnecessary where complainants allege only a finite number of occasions with detailed distinguishing features. Trial judges should not direct juries in a manner that presupposes the evidence relates to the charged acts where the Crown case has not been adequately particularised.
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