court held that the fact that the accused told a lie may be but is not necessarily corroboration. If a man tells a lie when he is spoken to about a certain offence, the fact that he told a lie at once throws grave doubt upon his evidence. If he afterwards gives evidence, it may be a good ground for rejecting the evidence.
However, the court found other strong corroborative statement including that of the accused which corroborated virtually all the children’s evidence except the indecency. On this the court said, it was not necessary to corroborate the whole of the evidence but only some material particular.
Corroboration of evidence of young children
One of the thorny issues in law relating to corroboration is the evidence of young children.
A conviction based on the uncorroborated unsworn evidence of a child is bad. The question is whether or not an unsworn evidence of a child can be corroborated by another evidence of another child, sworn or unsworn.
It has been argued that evidence which requires corroboration cannot itself corroborate (R. v MANSER, (1934). This argument was overruled in R v HESTER which held that an unsworn statement can only be corroborated by a sworn statement. In essence the unsworn statement of a child may be corroborated by a sworn statement of another child.
Consistently with this trend of thought, the House of Lord also decided that a sworn evidence of a child can corroborate another sworn evidence of another child (DPP v KILBOURNE [1973] AC 729).
See R. v CAMPBELL, where the court dealt with the issue of sworn evidence of children and more specifically whether the evidence of children who were assaulted would be corroboration for the evidence of other children that were assaulted. As explained by Lord Goddard,