Evidence of behavioural change proximate to alleged sexual offending may be used in three ways: to explain lack of complaint (context), to independently corroborate the offending (corroboration), or to bolster the complainant's credibility as consistent conduct (consistency). Where the prosecution invites the jury to use such evidence as consistency evidence, the trial judge must give appropriate directions, particularly where the evidence suffers from temporal imprecision, the conduct is of a general nature not necessarily indicative of sexual abuse, or there are alternative explanations for the behavioural changes. MCA v The State of Western Australia does not mandate a particular form of direction in every case involving behavioural change evidence.
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