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Judgment: The father appealed from a finding that he had sexually abused his daughter, on the basis that the judge had failed to apply the relevant legal principles to the evaluation of the child's evidence. Williams J found that the judgment was flawed and remitted the matter for further hearing, stating that "in relation to allegations of sexual abuse of young children the court must not only deploy the generic fact-finding approach but must in particular identify the need for special care to be taken in evaluating the reliability of the evidence of young children".

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