The case confirms that under s 4(5) of the Criminal Law (Sexual Offences) Act 1978 (Qld), evidence of a complainant's sexual activities is not proper matter for cross-examination as to credit unless 'special circumstances' exist that would be likely to materially impair confidence in the 'reliability' (not merely credibility) of the complainant's evidence. Evidence that merely suggests an alternative motive for the complainant to leave the premises does not, without more, constitute 'special circumstances'. The case also illustrates that differences in the quality of a complainant's evidence across different counts can logically explain acquittals on some counts and convictions on others without rendering the verdicts inconsistent.
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