In multiple complainant sexual offence cases, generalised similarities in the circumstances of offending (same professional setting, same type of vulnerability, same isolation) may be sufficient to establish cross-admissibility of sexual assault charges but may not meet the high threshold for cross-admissibility of rape charges where the specific conduct constituting the rapes differs significantly. The case illustrates the tension between the majority view that common features of the offending context can provide a sufficient link, and the dissenting view that stark differences in the specific conduct undermine any underlying pattern. The question of whether rape charges committed in similar professional settings are cross-admissible with sexual assault charges remains fact-dependent.
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