Evidence of prior uncharged conduct that falls short of established misconduct may be admissible on a non-tendency, non-coincidence basis where it is directly relevant to the accused's state of mind, particularly recklessness, and to rebut a defence. The Ivanoff principle is not limited to cases involving proven prior criminal conduct; it extends to cases where the accused was put on notice of the risk of criminal activity. The outer limits of the Ivanoff principle remain undefined.
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