judge erred in his analysis of the evidence, and that his reasons
 As I will explain below, I am of the view that the trial
judge’s reasons, when read as a whole, reflect that the trial
judge used the prior consistent statement for a limited, permissible purpose.
 The complainant’s verbal reaction to Constable Flint
advising her that she would be searched is presumptively inadmissible, because it is hearsay or, alternatively, because it is a
prior consistent statement. The statement, therefore, can only be
admissible if it falls within an exception to the hearsay rule, or
an exception to the prior consistent statement rule.
 The trial judge identified three possible routes of admissibility for the statement: ( i) admission under the traditional
hearsay exception of res gestae or spontaneous utterance;
( ii) admission under the principled approach to hearsay; and
( iii) admission as an exception to the rule against prior consistent statements. In my analysis of this issue, I will consider
all three routes. I will then analyze the permissible use of
A. Admissibility under the res gestae exception
 Res gestae statements are admissible as an exception to
the hearsay rule: R. v. Khan,  O.J. No. 578, 42 C.C.C. (3d)
197 (C.A.), affd  2 S.C.R. 531,  S.C.J. No. 81, at para.
21; R. v. Ratten,  A.C. 378,  3 All E.R. 801 (P.C.),
at pp. 389-91 A.C. Statements are admitted under this exception
to the hearsay rule on the basis that the stress or pressure
under which the statement is made can be said to safely discount the possibility of concoction: S. Casey Hill, David M.
Tanovich and Louis P. Strezos, McWilliams’ Canadian Criminal
Evidence, 5th ed. (Toronto: Canada Law Book, 2013), at
p. 7:120.20.10. The statement should be reasonably contemporaneous with the alleged occurrence, although exact contemporaneity is not required: Khan, at para. 25; R. v. Dakin, 
O.J. No. 944, 80 O.A.C. 253 (C.A.), at para. 20.
 The trial judge first addressed the admissibility of the
statement under the traditional exception to the hearsay rule of
res gestae or spontaneous utterance. He concluded that the
statement had a spontaneous quality and was admissible under
this exception, and rejected the respondent’s argument that, due
to her life experiences, the complainant had the ability to concoct the story of having been searched.