A conviction for a historic child sex offence may be upheld where the complainant was only three years old at the time of the alleged offending and the complaint was made over 30 years later, provided the jury's advantage in seeing and hearing the complainant is capable of resolving any doubt arising from the complainant's age and the delay. Defence counsel's decision not to call good character evidence will not constitute a miscarriage of justice where there is a real risk that the prosecution would adduce prejudicial rebuttal evidence of bad character, including allegations of domestic violence and sexual offending.
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