precise use of and value of the evidence of the prior consistent
statement in the specific circumstances of the case. I think an
approach based on the broader principles is much more likely to
focus the minds of counsel and the trial judge on exactly what
the evidence is said to do and the ability of the evidence to further that stated purpose. Instead of broad statements such as
“the evidence goes to credibility”, the principled approach should
produce reasons explaining exactly how the evidence, in the circumstances of the case, goes to credibility.
 When a party tenders a prior consistent statement, the
court must first determine the purpose for which that evidence
is tendered. If the evidence is tendered for its truth, in this case
to prove that the complainant was in fact searched three times
before she was to be searched at the police station, the evidence
must qualify for admissibility under the controlling hearsay
principles. My colleague has referred to those principles (see
 If the prior consistent statement is not offered for the
truth of its contents, the threshold admissibility question
remains the same — for what purpose is the evidence offered?
That purpose must be one which can properly be the subject
matter of evidence in the proceedings. In other words, the purpose must have relevance to a material issue in the proceeding.
 Once the purpose for offering the evidence is identified,
the party tendering the evidence must show that it has some
probative value in respect of the purpose for which it is offered.
For example, if it is said that the evidence of the prior consistent
statement is relevant to the complainant’s credibility, the party
offering the evidence must show how it is relevant to the complainant’s credibility.
 The operation of the approach I have outlined can be
described by reference to one of the most common situations in
which a prior consistent statement is tendered at trial. The
Crown may seek to elicit evidence of a statement made by a
complainant to the police shortly after an alleged assault. That
statement may be consistent with the complainant’s trial testimony. When the statement is offered, the first question in the
evidentiary inquiry must be — for what purpose is the evidence
offered? If the Crown argues that the statement is admissible
to prove as true the contents of the statement, the Crown must
establish that the statement is admissible hearsay.
 If the Crown does not suggest that the evidence is admissible to prove the truth of its contents, the Crown must identify
some other purpose for which the statement is offered. The
Crown may argue that the prior consistent statement supports