Narrative evidence

R. v. D.A.R., 2012 NSCA 31 has useful language regarding narrative evidence:

[23] Narrative evidence may be admissible for a variety of purposes: to understand the unfolding of events surrounding an offence (R. v. Magloir 2003 NSCA 74 (CanLII) <http://www.canlii.org/en/ns/nsca/doc/2003/2003nsca74/2003nsca74.html> , (2003), 178 C.C.C. (3d) 310 (N.S.C.A.), at para. 23); to explain why the abuse was not terminated by the victim or why the perpetrator was not reported to authorities (R. v. J.E.F. 1993 CanLII 3384 (ON CA) <http://www.canlii.org/en/on/onca/doc/1993/1993canlii3384/1993canlii3384.html> , (1993), 85 C.C.C. (3d) 457, at 11 (Ont. C.A.)); to test credibility (R. v. O.B., 1995 N.S.J. No. 499 (N.S.C.A.). In R. v. Assoun, 2006 NSCA 47 (CanLII) <http://www.canlii.org/en/ns/nsca/doc/2006/2006nsca47/2006nsca47.html> , 2006 NSCA 47, at para. 177, this Court endorsed the foregoing examples, amongst others:

[177] We agree with the Crown's outline of the purposes for which narrative evidence such as that of Ms. Gazzard may be relevant, and with its conclusion. The appellant has therefore not satisfied us on the first part of this argument, that Ms. Gazzard's contextual evidence was not relevant as narrative. Without her contextual evidence, in the form in which it was given as opposed to in a summary form, the jury would not have been able to properly evaluate the alleged admission or Ms. Gazzard's credibility and reliability.