Abstract
While Peter Ellis' posthumous appeal to the Supreme Court has rightly received significant attention for its role in developing the relationship between tikanga and the common law, comparatively little attention has been paid to the issues raised in the conviction appeal. This article considers whether the Court's decision signals a move away from the well-established approach of the Court of Appeal to the admissibility of expert evidence about the memory of child complainants. In addition, it examines whether the Supreme Court's assessment of the current state of the expert evidence conflicts with the legislative regime as presently formulated. The article ultimately concludes that given the continued uncertainty of the expert evidence in this area and the Supreme Court's refusal to confront these issues directly, the approach detailed in earlier Court of Appeal decisions will likely continue to guide trial courts.