The occurrence of sexual contact in the context of a 'game' with child complainants constitutes a common feature sufficient to satisfy the Bauer requirement for cross-admissibility of tendency evidence in multiple complainant sexual offence cases. Other features such as similar age of victims, familial relationship facilitating access, genital touching, and presence of another child further support significant probative value. Qualitative differences in the gravity of offending between complainants do not preclude cross-admissibility where common features exist.
The full text is available to signed-in members, including the 3 later cases that cite this judgment.
1 of the 3 citing cases carry a classified treatment. How each court treated it is available to signed-in members.