What is the test for admitting evidence in a civil case of false imprisonment?

The trial judge declined to admit the evidence under the principled exception to the hearsay rule or on the basis of res gestae. It is a nice question as to whether this evidence could have been admitted under the res gestae principle – see Ratten v. The Queen, [1971] 3 All E.R. 801 (P.C.), especially the comments of Lord Wilberforce at p.807. However, since the judge chose not to place admissibility on this criterion, I need not further consider this issue. He ruled that the evidence could be admitted to rebut a suggestion of recent fabrication by the complainants. He did not specifically comment on whether or not the evidence was being admitted as reflective of the state of mind of the complainants at the time they were speaking to the operator, although it would seem to me that the admissibility of this evidence to rebut a suggestion of recent fabrication would rest on the proposition that the evidence was demonstrative of the upset and frightened condition of the complainants and would thus tend to answer the suggestion in cross examination of recent fabrication.