The summary conviction appeal judge did not address
this route of admissibility in her reasons, perhaps because the
Crown conceded before the summary conviction appeal court
that the pre-conditions of the res gestae exception to the hearsay
rule were not met in this case. Given that concession, this route
of admissibility need not be addressed further.
B. Admissibility of the statement under the principled
 An excited utterance can also satisfy the principled
approach to the hearsay rule. The two requirements for the
admission of a hearsay statement under the principled approach
are reliability and necessity: R. v. Youvarajah,  2 S.C.R.
720,  S.C.J. No. 41, 2013 SCC 41, at para. 21. The reliabil-
ity of the statement comes from the absence of an opportunity to
concoct a story. As for necessity, where, as in this case, the wit-
ness testifies, the objection to hearsay statements arising from
the absence of an opportunity to cross-examine is negated. More
fundamentally, though, as pointed out by Justice Paciocco in
“The Perils and Potential of Prior Consistent Statements: Let’s
Get It Right” (2013), 17 Can. Crim. L. Rev. 181 (Paciocco), at
. . . [T]he “necessity” component [of the basic hearsay principles] performs a
“best evidence” function. It exists to ensure that if it is possible to present
“better evidence” in the form of in-court testimony, parties should not be
permitted to resort to hearsay proof . . . There are times, however, when
hearsay evidence is expressed under circumstances that yield tremendously
helpful criteria for evaluating the reliability or credibility of a factual claim.
 The trial judge concluded that, by virtue of its spontaneity, the statement was reliable, and that it met the necessity
requirement. The trial judge based his conclusion that the
statement was “necessary” on the fact that there had [
O.J. No. 6200, at para. 13] “been a direct attack on [the com-plainant’s] credibility by way of an allegation of complete fabrication” and her “professed lapses of memory or gaps of memory
with respect to portions of her evidence”.
 The summary conviction appeal court held that necessity
was not met in this case because the witness testified. The
summary conviction appeal judge stated, at para. 12:
Necessity is a component of the hearsay analysis along with reliability.
It often involves a recanting, dead or absconding witness who made the
prior consistent statement. If the witness does not attend at trial, it may
be necessary to admit the prior consistent statement to obtain the evi-
dence. Here, the complainant did give evidence at trial, so it was not neces-
sary to admit the prior consistent statement in order to obtain the evidence.