To 'abuse' a position of authority or trust under s 92P(1)(h) (now s 67(1)(h)) of the Crimes Act 1900 (ACT) means no more than to misuse the position for an improper purpose; the [name withheld] is not required to prove a specific act such as a threat or bribe connected to the position. Tendency and coincidence evidence directed at establishing a pattern of using a position of authority or trust to facilitate sexual contact is relevant to the issue of abuse of position and is not excluded by [name withheld] v R, which concerned tendency evidence directed at proving absence of consent simpliciter. Whether the accused was in a position of authority or trust is determined objectively and does not depend on the complainant's subjective recognition or articulation of the relationship.
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