Non-verbal conduct — including body language, facial expression, and the absence of a verbal denial — can constitute a 'disclosure' amounting to a 'complaint' for the purposes of s 4A of the Criminal Law (Sexual Offences) Act 1978 (Qld), though such conduct is at the borderline of what suffices. In cases of multiple penetrations of the one victim, a single complaint of rape is sufficient to found a preliminary complaint admissible under s 4A in respect of each penetration; separate complaints for each act are not required.
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