the complainant’s credibility. Clearly, the complainant’s credibility is material to the proceeding and is properly the subject matter of evidence at trial. It is not enough, however, for the Crown
to show that the complainant’s credibility is a material fact. The
Crown must also demonstrate how the prior consistent statement can impact positively on the complainant’s credibility. If
the Crown’s argument comes down to the suggestion that the
consistency between the prior statement and the complainant’s
evidence at trial justifies admissibility, the argument fails
because consistency on its own provides no insight into credibility. To know that the complainant made a statement that is consistent with his evidence at some earlier point in time simply
does not assist in the assessment of his credibility.
 The prior consistent statement can, however, become relevant to credibility if the assumed facts change somewhat. If the
defence challenged the complainant’s credibility, claiming he had
fabricated the allegation after being confronted by his boyfriend
about his relationship with the accused, evidence that the complainant made a prior consistent statement before his boyfriend
confronted him, would support the complainant’s credibility. The
prior statement would support the complainant’s credibility, not
because it is consistent with his testimony, but because it refutes
the defence claim that the complainant fabricated a false allegation in response to being confronted by his boyfriend. By neutralizing the reason advanced by the defence for the fabrication
of the allegation, the evidence has the effect of supporting the
 The trial judge held that the complainant’s prior consistent statement to Constable Flint that she had been searched
three times was relevant in that it assisted in assessing the
complainant’s credibility. I think he was right. On the approach
I have set out above, the reasoning goes as follows.
 I begin with the substance of the complainant’s evidence.
She testified that she was searched by the respondent three times
in the police cruiser. The first two searches did not concern
her. The complainant was unfamiliar with police practices and
assumed that the respondent was following established procedures. During the third search, the respondent shone a flashlight
down her shirt and looked at her breasts. The complainant told
the officer that this made her uncomfortable and he stopped.
 On the complainant’s evidence, she did not know if the
respondent’s actions constituted a sexual assault. She had no
intention of alleging that the respondent had sexually assaulted
her, or complaining about his behaviour when she arrived at the
police station. In her testimony, the complainant presented as