Recorded prison phone calls in which an accused attempts to persuade a complainant to withdraw a complaint — without ever asserting the complaint is false or raising the defence later advanced at trial — constitute powerful consciousness of guilt evidence capable of undermining the accused's version. An effective sentence of eight years' imprisonment for three counts of rape, sexual assault, choking, and breach of a domestic violence order committed in a single protracted episode in a domestic relationship is within the appropriate range. Pre-2016 comparable sentences for domestic violence offences may need reconsideration in light of the Criminal Law (Domestic Violence) Amendment Act 2016.
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