Conviction appeal on charges of assault and sexual assault. Jury trial. Accused and complainant were husband and wife. Defence raised credibility concerns regarding the complainant’s testimony. Argument on appeal was that the jury ought to have been given a Vetrovec warning.

Held: Appeal dismissed.

“A Vetrovec warning is usually appropriate in cases dealing with ‘unsavory’ witnesses … While a Vetrovec warning is not restricted to cases of traditional unsavory witnesses, it is not required in every case simply because the complainant’s credibility is in issue … A complainant in a domestic abuse case does not typically bear the hallmarks of classic Vetrovec witnesses.”

B. Der – Defence Counsel