Maynard v The State of Western Australia

Maynard was convicted following a trial for unlawfully causing grievous bodily harm. The appellant appealed the conviction, arguing that the trial judge erred in admitting a prior consistent statement made by the complainant. The appeal was heard in the Court of Appeal of the Supreme Court of Western Australia. The central issue for the court was whether the trial judge erred in ruling that the complainant's prior consistent statement was admissible under the doctrine of recent fabrication or invention.

The court considered whether the statement was indeed a prior consistent statement and whether it was admissible under the doctrine of recent fabrication or invention. The court noted that the statement was made by the complainant before any suggestion of fabrication, and was consistent with the evidence given at trial. The court also considered whether the statement was relevant and whether its probative value outweighed any prejudicial effect. The court held that the trial judge did not err in admitting the statement as it was relevant and its probative value was not substantially outweighed by any prejudicial effect.

The court rejected the appellant's argument that the statement was inadmissible as it was a recent fabrication. The court found that the statement was not a recent fabrication as it was made before any suggestion of fabrication. The court also found that the statement was relevant to the issues in the case and its probative value was not substantially outweighed by any prejudicial effect. The appeal was dismissed.