Inconsistencies in child complainants' evidence that are explicable by the circumstances of initial disclosure (brevity of first police conversation, age of complainant, structure of VARE questioning) are not material inconsistencies warranting appellate intervention. The fact that a child complainant's evidence was influenced by a parent's remark about the accuracy of a prior account does not, without more, render the evidence 'of a kind that may be unreliable' for the purposes of s 32 of the Jury Directions Act 2015 (Vic), where the influence was exposed in evidence and cross-examination and was within the jury's ordinary capacity to evaluate.
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