A child complainant's written statement is admissible under s 93A Evidence Act 1977 (Qld) as circumstantial evidence tending to establish a sexual relationship, but the jury must be directed on the need to be satisfied the statement refers to physical sexual interaction and to exclude the possibility it refers to lesser conduct. Where a Robinson direction is given in a case of prolonged child sexual abuse, the circumstances warranting specific reference in the warning are those giving rise to a perceptible risk of miscarriage of justice, not merely those capable of supporting rival arguments in addresses. Arguments that a child complainant's failure to make full disclosure at early opportunities undermines credibility are inconsistent with s 4A Criminal Law (Sexual Offences) Act 1978 (Qld) and the recognised reality that disclosure of sexual abuse is a harrowing experience for a child.
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