In a criminal prosecution for sexual assault, the Crown brought a motion to admit two alleged prior consistent statements made by the complainant to third parties.
The Crown argued the statements were admissible under the narrative exception to explain the timing and fact of the complaint.
The court reviewed the governing principles that prior consistent statements are generally inadmissible except for limited purposes such as narrative context.
The statement made to one witness was found to be vague, lacking detail, and too remote in time to form part of a narrative, and was excluded.
The statement made to another witness, who was present on the night of the alleged incident and could identify the circumstances with specificity, was admitted for the limited purpose of establishing the fact and timing of the complaint.
