The accused, Amari Buchanan, faced charges including criminal harassment, trafficking in persons, and threatening bodily harm.
The Crown sought to admit two videotaped cautioned statements of the recanting complainant, J.J., for their truth under the principled exception to the hearsay rule (Khelawon application).
J.J. testified as a hostile witness, denying her prior allegations and claiming police pressure, drug influence, and memory loss due to a concussion.
The court found J.J.'s testimony lacked credibility, her memory loss contrived, and her hostility transparently aimed at exonerating the accused.
The court concluded that the police statements met the threshold reliability test, finding that J.J. appreciated the seriousness of her statements and the consequences of lying, and that the videotapes allowed for assessment of her demeanour.
The statements were admitted for their truth.
