Exculpatory statements made on arrest may be admissible

A spontaneous exculpatory statement made directly on arrest may be admissible if the accused testifies:

R. v. Edgar, 2010 ONCA 529:

[24]         For the following reasons, I conclude that the spontaneous exculpatory statements made by an accused person upon or shortly after arrest may be admitted as an exception to the general rule excluding prior consistent statements for the purpose of showing the reaction of the accused when first confronted with the accusation, provided the accused testifies and thereby exposes himself or herself to cross-examination