[2001] EWCA Crim 644

Where there was a previous account by a complainant before a jury which did not of itself constitute evidence, but to which the jury was likely to have regard in reaching a verdict, the jury had to be directed that recent complaints were not evidence of what happened but could at best be treated as admissible to establish consistency with the evidence of the complainant given at trial.

CA (Crim Div) (Potter LJ, Stanley Burnton J, Sir Rhys Davies QC)


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