Complaint evidence under s 34M(6) of the Evidence Act 1929 (SA) must be sufficiently specific to establish that the complaint related to sexual offending against the complainant herself and to the charged offences; nebulous evidence of conversations with police and counsellors is insufficient. Where uncharged acts are admitted as 'relationship evidence', the trial judge must give a specific direction on the impermissible purpose of that evidence (propensity reasoning), and a direction on the impermissible use of cross-admissible evidence is not sufficient. Forensic disadvantage directions under s 34CB must not be diluted by reference to difficulties faced by prosecution witnesses, must not invite the jury to assume complainants are doing their best to tell the truth where the defence is deliberate fabrication, and must not suggest the complainants suffered the same forensic disadvantage as the accused. For cross-admissibility in multi-complainant sexual offence cases, it is insufficient that the accused is the 'common denominator'; there must be demonstrated underlying unity or specific propensity connecting the offences.
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