Prior consistent statements

R. v. R.H., 2010 ONCA 758, released today online, is a useful source for the rule against the use of prior consistent statements:

[3]              Generally, it is not open to Crown counsel to lead evidence of prior consistent statements from a complainant during her examination-in-chief.  Statements such as those made by the complainant, in this case to her school friends, which were made many years before the complaint was made that led to charges being laid, are not admissible as narrative in accordance with this court's decision in R. v. F. (J.E.) (1993), 16 O.R. (3d) 1.  Ordinarily, it is not open to the Crown to lead evidence of prior consistent statements simply in anticipation that the defence may allege recent fabrication: see R. v. R. (S.) (1992), 8 O.R. (2d) 679 (Ont. C.A.).