In a judge-alone criminal trial, where the complainant's evidence is contradicted by an independent witness on a matter going to the core of the alleged offence, the trial judge must specifically address and resolve that inconsistency in the reasons; a general reference to having considered inconsistencies is insufficient. Where the failure to give adequate reasons relates to the central issue of the complainant's credit, the proviso to s 6(1) of the Criminal Appeal Act 1912 (NSW) will not save the conviction if the appellate court cannot independently assess the complainant's credibility from the record.
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