Where a pretext call in a sexual offence case involves only the charged offences and no uncharged acts, the principles in R v IE, R v BBQ and R v BCQ requiring specific directions on the standard of proof before treating statements as admissions do not apply. A Markuleski direction is not required in every case of multiple counts; it depends on whether the evidence about each count is materially different. Cannabis use by a complainant does not require a specific judicial warning absent direct evidence linking consumption to the events in question or expert evidence on its effects on reliability.
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