¶1(concurring in the result). I am in complete accord with the result but in disagreement with a phase of the majority opinion as it deals with a ruling on evidence.
¶2The principle of recent fabrication is one by which evidence of prior consistent statements is permitted to rehabilitate the credibility of a witness. The principle has potential danger, but under strict safeguards against its indiscriminate application it will, in proper circumstances, work justice.
¶3I cannot agree, however, with the analysis of the *424principle as made in the opinion. The majority take the view that the so-called recently fabricated statement is the inconsistent statement made shortly before trial, as disclosed by cross-examination of the witness. This is inaccurate and may lead to difficulties.
¶4The statement of the witness on direct examination is the one to have in mind. This is the testimony that is referred to in the principle as having been recently fabricated. In short, the principle will permit proof of prior consistent statements, made at or about the time when the narrated events occurred and when no motive was present to falsify, to meet the claim that an inconsistent statement made shortly before trial demonstrates that the direct testimony of the witness has been recently fabricated. 58 Am. Jur. 464, § 828, and cases cited.