Section 229B(2) of the Criminal Code (Qld) does not require that sexual contact reach a minimum level of invasiveness or occur with a minimum frequency in order to constitute a 'relationship'. It is the continuity or habituality of sexual contact that may give rise to a relationship, and 'low level' physical contact of a sexual nature is capable of evidencing such a relationship. A Robinson direction is not required where the complainant was not a very young child, there was no exceptional delay, no relevant illness or disorder, and inconsistencies were addressed in the summing up.
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2 of the 4 citing cases carry a classified treatment. How each court treated it is available to signed-in members.