In multi-complainant sexual offence cases in Queensland, the fact that one complainant was of an age capable of consenting does not create a relevant distinction that defeats cross-admissibility where no consent was given and there was no basis to infer the accused believed consent might be forthcoming. The Pfennig test is satisfied where the offending against each complainant shares features of brazenness, opportunism, similar nature of assault, and similar circumstances (offending in the accused's home against friends of his children while others were present). 'Relationship evidence' and 'motivation evidence' bases for admission of similar fact evidence are confined to evidence involving the same complainant.
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