In multi-complainant historical sexual offence cases, tendency evidence of uncharged acts committed at different institutions over an extended period may be cross-admissible where the acts share common features such as the offender's position of authority over young inmates in institutional settings, even where there is a gap of several years between the two groups of acts, provided the gap is explicable by absence of opportunity. The Bauer principle that juries should not ordinarily be directed to apply the beyond reasonable doubt standard to uncharged acts applies equally in multi-complainant cases. The Todd principle regarding delay does not apply where the offender exploited victims' vulnerabilities to deter complaint.
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