Prior to April 1, 1955, in the case of certain sexual offences, the common law required a trial judge to caution the jury on the dangers of convicting on the uncorroborated evidence of the complainant. This requirement was described as a rule of practice: see Thomas v. The Queen (1952), 1952 CanLII 7 (SCC), 103 C.C.C. 193 at p. 199, [1952] 4 D.L.R. 306, [1952] 2 S.C.R. 344, per Cartwright J. When s. 134 (later to become s. 142) of the new Criminal Code came into effect, the requirement for such a caution became a rule of law in the case of certain sexual offences including rape and indecent assault on a female.
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