When does evidence need corroboration? (Criminal Procedure cases)

XP, a teacher in charge of water polo, was accused of molesting the young boys in his team. D and E both claimed that XP had molested them on separate occasions, but nobody else could corroborate what they had said. Could XP be convicted on D's evidence or E's evidence alone, without corroboration? Could D and E corroborate one another?

The court said "(2) There was no formal legal requirement for corroboration under s 136 of the Evidence Act where a case turned on the complainant’s word against that of the accused. ... a complainant’s testimony had to be unusually convincing in order to prove the Prosecution’s case beyond a reasonable doubt without independent corroboration" Does the complainant in sexual offence cases need corroboration?

The problem in such cases is that the complainant is often the only witness, and there are no other witnesses. The courts have decided that corroboration is not required every time - Kwang Peng Hong v PP [2000] 4 SLR 96

However, must be unusually convincing - Teo Keng Pong v PP [1996] 3 SLR 329 and Lee Kwang Peng v PP [1997] 3 SLR 278

A child witness may need corroboration. "It is a sound rule in practice not to act on the uncorroborated evidence of a child, whether sworn or unsworn, but this is a rule of prudence and not of law" - Chao Chong v PP [1960] MLJ 238

So it is in fact possible to convict based on uncorroborated evidence of a child, if it is convincing enough. In the following case, even though there were more than one child, the court did not rely on them to corroborate one another, because the accused had claimed they were colluding. Instead the court decided that each child was convincing enough. Otherwise if the child appears to be immature or unreliable, the court will not convict based on his uncorroborated evidence


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