Where a defendant gives sworn evidence denying the offending in a sexual offence case that depends on the complainant's credibility, the trial judge must give a specific direction on the significance of the defendant's evidence and must direct that even if the jury rejects the defendant's evidence, they must still be satisfied beyond reasonable doubt of the complainant's evidence before convicting; general onus of proof directions are insufficient. Where discreditable conduct evidence arises unexpectedly during re-examination, the trial judge should permit the defence to recall the complainant for further cross-examination, particularly where the evidence is potentially powerful and the prosecutor does not object. Where oath-belief evidence or evidence of prior false accusations is given, the trial judge must direct the jury on how that evidence may be used in assessing the complainant's reliability.
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