A disclosure to a third party about a specific sexual offence constitutes a preliminary complaint under s 4A of the Criminal Law (Sexual Offences) Act 1978 (Qld) even where the complainant has already given a formal witness statement to police about other, different offences arising from the same sexual relationship. The only formal witness statement that excludes a subsequent complaint is one given in relation to the same alleged offence. A trial judge is not required to provide a count-by-count summary of the complainant's evidence in a multi-count sexual offence trial where detailed particulars of charges are available to the jury throughout the trial and the evidence was heard relatively recently before deliberations.
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