Relationship evidence admitted under s 132B(2) of the Evidence Act 1977 (Qld) to provide context (not propensity) does not require a propensity warning where the evidence was not tendered for that purpose and such a warning would be forensically counterproductive. A Robinson direction is not required where the credit arguments are obvious from cross-examination and the defence address, and there is no perceptible risk that the jury would be unable to appreciate exculpatory factors without specific judicial assistance. However, care must be taken in framing directions on relationship evidence to avoid language suggestive of propensity reasoning.
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