The Court held that It would only be in the rarest cases that expert or opinion evidence from a counsellor would be relevant or admissible. The starting point was always that a counsellor's evidence went only to fact. That factual evidence would be restricted to the timing and nature of any complaints made during the counselling sessions. When giving that evidence, a counsellor had to take great care to use objective language and avoid saying anything that could be construed as subjective comment or personal opinion.
An independent counsellor who had not seen the witnesses could only give opinion evidence about counselling techniques and qualifications, and could not give evidence about the cause of any psychological or psychiatric condition, or comment on the truth or otherwise of the allegations, R. v C  EWCA Crim 1478,  7 WLUK 169 applied. Leaving aside the question of whether it was truly an expert field, it would only be in a very rare case, where for example there was a dispute about the counselling techniques that had been adopted and which mattered, perhaps because it affected the value of a counsellor's factual evidence, that expert counselling evidence would ever be relevant, and therefore admissible. The principal reason why evidence from counsellors was admissible at all was evidence of fact, not of the allegations themselves, but in order to show that the complaints were made at the time of the events or shortly thereafter