R v. L.O. [2015] O.J. No. 2956 (CA – Doherty):

[34] L.F.’s prior consistent statements were also relevant to the jury’s assessment of the reliability of her evidence in a second, less direct way. Consistencies in her statements provided important context to assess the defence attack on L.F.’s reliability based on alleged inconsistencies.

[35] The trial judge correctly told the jury that prior inconsistencies were relevant to the reliability of L.F.’s testimony and to her credibility. She also told the jury, again correctly, that the significance of inconsistencies in the assessment of L.F.’s reliability and credibility could only be determined after an examination of the nature and extent of those inconsistencies. An isolated, minor inconsistency in a sea of otherwise consistent descriptions of the relevant events would have far less impact on L.F.’s credibility and reliability than would several material inconsistencies going to the heart of her allegations.

[36] The jury had to consider the entirety of the evidence relating to L.F.’s various statements, including the consistencies in those statements, in deciding the impact of any inconsistencies in those statements on her credibility and reliability. To the extent that L.F.’s statements were con-sistent, especially on the central features of the allegations, that consistency could counter, or at least mitigate, the defence claim that L.F. was not credible or reliable because of her many prior inconsistent statements: see D.M. Paciocco, “The Perils and Potential of Prior Consistent Statements: Let’s get it Right” (2013) 17 Can. Crim. L. Rev. 188, at p. 199.