| SUPREME COURT OF VICTORIA COURT OF APPEAL |
| S EAPCR 2021 0185 |
| AJP (A PSEUDONYM)[1] | Applicant |
| v | |
| THE QUEEN | Respondent |
[1]To ensure that there is no possibility of identification of the victims of sexual offending, this judgment has been anonymised by the adoption of a pseudonym in place of the name of the applicant.
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| JUDGES: | PRIEST, McLEISH and WALKER JJA |
| WHERE HELD: | Melbourne |
| DATE OF HEARING: | 22 August 2022 |
| DATE OF JUDGMENT: | 2 September 2022 |
| MEDIUM NEUTRAL CITATION: | [2022] VSCA 187 |
| JUDGMENT APPEALED FROM: | [2012] VCC 1830 (Judge Campton) |
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CRIMINAL LAW – Appeal – Conviction – Fresh evidence – Applicant convicted in 2012 of common assault, incest and making threat to kill – Incest charge based on allegation that applicant inserted blunt object into complainant’s anus – Expert evidence adduced at trial that complainant had anal fissure which could be caused by insertion of blunt object, as well as by other things – Complainant told police he had never done anything that could have caused any injury to his anus – Complainant gave evidence that he told no one about abuse until 2008 – Complainant gave evidence at later, unconnected committal that he had inserted object into own anus on different occasion – Complainant also gave evidence at later committal that he told another person about abuse before 2008 – Fresh evidence could have affected jury’s assessment of complainant’s credibility – Evidence could have provided alternative explanation for complainant’s injury – Substantial miscarriage of justice because fresh evidence gave rise to significant possibility jury would have acquitted if evidence available at trial – Sentence already served in full – Appeal allowed – Orders for acquittal.
Criminal Procedure Act 2009, ss 276, 277.
R v Nguyen & Tran [1998] 4 VR 394; R v A2 (2019) 269 CLR 507, applied.
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| Counsel | |||
| Applicant: | Ms CA Boston and Ms H Canham | ||
| Respondent: | Mr CB Boyce QC | ||
Solicitors | |||
| Applicant: | Leanne Warren & Associates | ||
| Respondent: | Ms A Hogan, Solicitor for Public Prosecutions | ||
TABLE OF CONTENTS
PRIEST JA
MCLEISH JA
WALKER JA:
(1).... Introduction
(2).... Relevant principles
(3).... The parties’ submissions
(4).... Relevance and admissibility
(5).... Significant possibility of acquittal?
(a) The evidence concerning the anal fissure
(i) The first complaint to police
(ii) Dr Stillger’s examination
(iii) The complainant’s 2010 statement to police
(iv) The complainant’s evidence at the applicant’s committal
(v) Dr Parkin’s examination of the complainant
(vi) The complainant’s evidence at the applicant’s trial
(vii) The complainant’s mother’s evidence at the applicant’s trial
(viii) Dr Parkin’s evidence at the applicant’s trial
(ix) The prosecution’s closing address
(x) Defence counsel’s closing address
(xi) The judge’s charge
(b) The bike pump evidence
(c) Did the bike pump evidence raise a significant possibility of acquittal?
(i) The complainant’s credibility
(ii) The causation issue
(d) The evidence about first complaint
(6).... Conclusion
PRIEST JA
I agree with Walker JA.
MCLEISH JA
I agree with Walker JA.
WALKER JA:
(1)Introduction
In 2012 the applicant was convicted of one charge of common…
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- AJP (a pseudonym) v The Queen [2022] VSCA 187
- Case
- [2022] VSCA 187
- Decision Date
CaseChat Overview and Summary
The court was required to determine whether the fresh evidence was of such a nature that, if it had been available at the time of the trial, it would have led the jury to acquit the applicant. The court considered the potential impact of the fresh evidence on the jury’s assessment of the complainant’s credibility and whether there was a significant possibility that the jury would have acquitted the applicant if the evidence had been available. The court also had to decide whether to order a retrial or enter a verdict of acquittal.
The court found that the fresh evidence could have affected the jury’s assessment of the complainant’s credibility and provided an alternative explanation for the anal injury. The court concluded that there was a significant possibility that the jury would have acquitted the applicant if the fresh evidence had been available at the time of the trial. The court also considered factors such as the applicant having served his entire sentence, the lengthy delay between the alleged offending and any potential retrial, and the respondent’s concession to enter verdicts of acquittal. Based on these considerations, the court allowed the appeal and set aside the applicant’s convictions on all charges, ordering judgments of acquittal to be entered.
Orders
Orders of the court
Full text does not contain this section.
Background
Background to the litigation
Full text does not contain this section.
Evidence
Evidence Before The Court
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
The judge dealt with Dr Parkin’s evidence concerning the anal fissure at several different places in her charge. First, she explained that Dr Parkin was permitted to give opinion evidence because of her expertise. Second, she referred to Dr Parkin’s evidence when directing the jury about inferences, as follows:You have heard evidence in this case about the anal fissure that the accused had when Dr Stillger examined him in 2009 — sorry, the complainant had in 2009. You have heard evidence from Dr Parkin of scar tissue which was in more or less the same position when she examined the accused. As defence counsel quite rightly pointed out [in her] closing address, you have also heard evidence of the [complainant], as a young child, having a history of, I suppose you could refer to it as chronic constipation. You have heard evidence from Dr Parkin that there are a number of causes for or that could be responsible for someone having an anal fissure and they include explosive diarrhoea, Crohn’s disease, and constipation. In other words, if we go back to the example that I have given you about the danger of drawing inferences, you will see in this case that while you might say that penetration by an object could cause an anal fissure, so could explosive constipation, so could Crohn’s disease, and so could explosive diarrhoea. In this case, the matter becomes even more important that you do not draw an inference where it is not appropriate, given that the evidence is that the complainant in this case has a history, as a young child, of chronic constipation, and also a history of penetration of his anus by possibly doctors or nurses to get out impacted faeces. So, that is a really important direction I have given you in relation to the drawing of inferences.[16] [16]Emphasis added. Later in her charge, the judge returned to the medical evidence in the course of summarising the evidence, as follows:Now, you heard — this case you heard some evidence in relation to a medical condition that the accused suffered from and that was the anal fissure and Dr Parkin gave some evidence about that. I am just going to summarise what she said. I am not going to go through all her evidence and all her cross-examination but I will be bringing some — there were some issues which I am going to bring to your attention. In summary, she said that on examination she found evidence of scar tissue in what she called the 6 o’clock position of the anus and she said that scar tissue indicated that there may have been a fissure there. She said that a fissure is a tear or laceration in the perimetral area which is the pigmented area outside the anus that you can actually visualise. She said that there was no way that a doctor is able to age an anal fissure with any degree of certainty. And she said there were multiple explanations for a fissure including blunt force trauma, constipation, explosive diarrhoea, Crohn’s disease, inflammation. Cross-examination — she agreed the most she could say was that the anal fissure which she had not actually observed because she saw the scar tissue could have been consistent with some form of trauma to the anus of the complainant.[17] [17]Emphasis added.