A direction that the jury must be satisfied beyond reasonable doubt that the defendant maintained an unlawful sexual relationship involving more than one unlawful sexual act is sufficient without a separate direction that each individual uncharged act must be proved beyond reasonable doubt. Evidence of a complainant's disclosure to a third party does not constitute a preliminary complaint under s 4A of the Criminal Law (Sexual Offences) Act 1978 (Qld) where the complainant did not relate the act constituting the offence charged or any other sexual act, and no preliminary complaint direction is required in respect of such evidence.
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