As noted above, the necessity requirement under the
principled approach does not require that the witness be absent
or unable to give evidence. Rather, the necessity requirement
can be satisfied where the witness is unable to give a full and
frank account of the events, or where the witness has difficulty
recalling significant details of the event: Khan; R. v. C. (M.),
 O.J. No. 3959, 2014 ONCA 611, 314 C.C.C. (3d) 336,
at para. 56.
 That being said, the trial judge’s analysis of necessity was
problematic. While lapses in memory can, in some circumstances,
satisfy the necessity requirement under the principled approach,
an attack on a witness’ credibility generally does not satisfy the
necessity requirement of the principled approach.
 Although not for the reason identified by the summary
conviction appeal judge, I am of the view that necessity was not
met, and thus the statement is not properly admitted under
the principled approach. The complainant testified consistently
about the essential parts of the allegations. Whatever lapses
may have existed in her memory, they did not go to the essential
details of the allegation that she had been previously searched
numerous times. The record does not establish that the complainant was unable or unwilling to give a full account of events,
or could not recall significant details of the event. The necessity
component of the principled approach to hearsay is not satisfied.
 Therefore, the statement is also not admissible for the
truth of its contents under the principled approach to hearsay.
What remains is whether the statement is admissible as an
exception to the general rule against the admission of prior consistent statements.
C. Admissibility as an exception to the rule against prior
 Prior consistent statements are presumptively inadmissible because they lack probative value: R. v. Stirling, 
1 S.C.R. 272,  S.C.J. No. 10, 2008 SCC 10, at paras. 5-7.
The fact that someone said the same thing on a prior occasion to
what he/she has said in court is, generally speaking, not probative of whether the witness is offering truthful testimony in
court. It would be self-serving to allow a witness to buttress his
or her own testimony with her own prior statements.
 As Watt J.A. noted in C. (M.), at para. 59, citing Paciocco,
at p. 184, prior consistent statements are an amalgam of two
elements — the hearsay element and the declaration element.
The hearsay rule takes care of the hearsay element. The prior
consistent statement rules generally exclude the declaration