Allen (a pseudonym) v The Queen

Case [2016] VSCA 59


SUPREME COURT OF VICTORIA

COURT OF APPEAL

S APCR 2015 0090

NICOLAS ALLEN (A PSEUDONYM)[1] Applicant
v
THE QUEEN Respondent

[1]To ensure that there is no possibility of identification, this judgment has been anonymised by the adoption of a pseudonym in place of the name of the applicant.

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JUDGES: MAXWELL P, REDLICH and PRIEST JJA
WHERE HELD: MELBOURNE
DATE OF HEARING: 5 February and 7 March 2016
DATE OF JUDGMENT: 31 March 2016
MEDIUM NEUTRAL CITATION: [2016] VSCA 59
JUDGMENT APPEALED FROM: DPP v [Allen] (Unreported, County Court of Victoria, Judge Smallwood, 20 January 2014 (Conviction))

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CRIMINAL LAW — Appeal — Conviction — Incest and indecent assaults — Conduct of defence counsel — Forensic decision to allege collusion between complainant and mother — Duties of counsel — Absence of instructions or evidence of collusion — No rational forensic benefit for  pursuing  explanation  of collusion — Warning by trial judge that such cross examination  would likely result in  introduction of prejudicial bad character evidence — Failure to sufficiently  challenge  trial judge’s view — Evidence of bad character admitted — Failure of judge to preclude admission of irrelevant prejudicial  evidence — Substantial miscarriage of justice — Appeal allowed — Retrial ordered.

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APPEARANCES: Counsel Solicitors
For the Applicant Mr D Dann SC and
Mr H Venice
Valos Black & Associates
For the Crown Mr D Trapnell QC
(5 February 2016);
Mr C Boyce SC
(7 March 2016)
Mr J Cain, Solicitor for Public Prosecutions

MAXWELL P
REDLICH JA
PRIEST JA:

Summary

  1. In the applicant’s trial for serious sexual offences, his counsel advanced a ‘defence’ that the complainant had colluded with her mother to make false allegations of sexual impropriety against him.  The suggested motive for the two colluding was a desire to effect cancellation of the applicant’s parole.  The  trial judge warned counsel that if he advanced such an explanation, it was likely that evidence of the applicant’s bad character would  emerge, and made it clear that he would not prevent the admission of such highly prejudicial evidence.  Despite the judge’s  warning, counsel determined to pursue the explanation and put a positive assertion of collusion to the complainant’s mother.

  1. During counsel’s cross-examination, and the prosecutor’s re-examination, of the complainant’s mother,  evidence was adduced that the applicant had previously been involved in discreditable conduct of a serious nature, including violence towards the complainant’s mother and her children, and had been imprisoned for the commission of very serious offences.  The evidence was inflammatory and highly prejudicial, and had little or no probative value.  Thus, the very consequences foreshadowed by the judge were permitted to occur.

  1. As counsel had neither instructions nor evidence to support a positive assertion of collusion, the assertion should not have been made.  Further, there was no forensic benefit that could be derived from pursuing that allegation.  Moreover, counsel failed adequately to resist the admission of irrelevant and highly prejudicial evidence.  He asked open-ended questions, which resulted in the admission of much of the extremely prejudicial evidence.  And the…

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AGLC
Allen (a pseudonym) v The Queen [2016] VSCA 59
Case
[2016] VSCA 59
Decision Date

CaseChat Overview and Summary

The appeal concerns the conviction of the applicant, Allen, for incest and indecent assaults, with the decision of the court being delivered by the High Court of Australia. The core of the dispute lies in the conduct of the defence counsel during the trial, specifically in the decision to allege collusion between the complainant and her mother, leading to the introduction of prejudicial evidence of bad character. This evidence was deemed highly prejudicial and irrelevant, which subsequently resulted in the admission of prejudicial material suggesting the applicant's bad character, including a propensity for violence.

The primary legal issue before the court was whether the conduct of the defence counsel, in pursuing the allegation of collusion between the complainant and her mother, was justified under the Evidence Act 2008. The court examined whether there were rational grounds for this line of inquiry, given the absence of instructions or evidence of collusion. Additionally, the court had to determine if the trial judge erred in allowing the prejudicial evidence of bad character, and whether this constituted a substantial miscarriage of justice. The court noted that under the Evidence Act, evidence of an accused's bad character is not admissible unless the accused has provided evidence to prove their good character, either generally or in a particular respect.

The court found that the defence counsel's decision to pursue the allegation of collusion was improper and forensically unwise. The court held that there were no rational grounds for this line of inquiry, as there were no instructions or evidence to support the allegation of collusion. Furthermore, the court emphasised that the admission of evidence of bad character was unwarranted and prejudicial. The trial judge's failure to preclude the admission of this irrelevant and prejudicial evidence was considered a substantial error. Consequently, the appeal was allowed, and a retrial was ordered to rectify the substantial miscarriage of justice.

Orders

Orders of the court

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Background

Background to the litigation

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Evidence

Evidence Before The Court

In the written case filed in support of the present application, counsel for the applicant[20] submitted that it can now be seen that the consequences of the applicant’s trial counsel pursuing the ’breach of parole’ theory in cross-examination of BNK ‘were most unfortunate’. So much cannot be gainsaid. That misfortune resulted from the combination of counsel’s improper and forensically unwise pursuit of the collusion allegation and the approach taken by the trial judge to the introduction of the irrelevant and highly prejudicial evidence.[20]Counsel in this Court was not counsel at trial. The trial judge’s view that prejudicial evidence of bad character could be admitted At the risk of repetition, the defence case was that WLK and her mother had colluded to make false allegations against the applicant, so that his parole would be breached and he would be imprisoned. Self-evidently, the advancement of that defence involved revealing that the applicant had previously been imprisoned, and it involved an attack on the credit of both WLK and BNK. Despite the apparently strongly-held (and strongly-expressed) views of the trial judge, however, neither of those aspects justified a ventilation of the reasons for the applicant’s imprisonment, or the introduction of grossly prejudicial material suggesting the applicant’s bad character (including a propensity for violence). Subsections 110(2) and (3) of the Evidence Act 2008 make plain that evidence that an accused person is not of good character, either generally or in a particular respect, is not admissible unless the accused has adduced evidence to prove (directly or by implication) that the accused is, either generally or in a particular respect, a person of good character. Quite obviously, that part of the ‘defence’ that revealed that the applicant was on parole was not evidence of his good character. Nor did the suggestion of collusion raise his good character. Although expressed in relation to a different statutory regime, the various principles distilled in Thomas,[21] bearing on the introduction of evidence of bad character, remain apposite:[22] The principles conveniently summarised in Thomas raise no new or novel propositions of law. It might reasonably have been expected that counsel and judge should have been acquainted with them. For that reason, it is difficult to understand how it could have been thought that any defence suggestion of collusion could have opened the defence up to — as the judge colourfully put it — a ‘mouthful’. There are some parallels between this case and Steve,[23] a decision of the New South Wales Court of Criminal Appeal. In that case, the appellant was convicted of sexual intercourse without consent. He had been represented at trial by a ‘country solicitor’, who had failed to object to irrelevant and highly prejudicial evidence elicited from prosecution witnesses both by the prosecutor in evidence in chief, and by the solicitor in the course of his cross-examination. The consequence of the admission of some of that evidence was that the jury was left with evidence that the appellant was a person of a violent disposition towards women, with a history (albeit non-specific) of ‘putting the hard word on’ women, and who was a ‘paedophile’.[24] [23]Steve v The Queen (2008) 189 A Crim R 68 (‘Steve’).[24]Ibid 83 [81].

Decision

Reasons for decision

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Ratio Decidendi

Legal Principle Established

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