SUPREME COURT OF VICTORIA
COURT OF APPEAL
No 713 of 2008
| FRANK BABIC |
| v |
| THE QUEEN |
---
| JUDGES | ASHLEY, NEAVE and HARPER JJA |
| WHERE HELD | MELBOURNE |
| DATE OF HEARING | 25 May and 3 June 2010 |
| DATE OF JUDGMENT | 17 August 2010 |
| MEDIUM NEUTRAL CITATION | [2010] VSCA 198 |
| JUDGMENT APPEALED FROM | [2008] VSC 218 (King J) |
---
CRIMINAL LAW – Conviction – Application for leave to appeal – Murder – Self defence – Defensive homicide –Whether common law self defence abolished – Effect of amendments introduced by Crimes (Homicide) Act 2005 – Whether jury directions as to defensive homicide incorrect and deprived applicant of conviction of defensive homicide – Interpretation of Crimes Act 1958, ss 9AC, 9AD – Whether judge failed to relate applicant’s intoxication to issue of intent – Whether judge erred in referring to ‘imminent threat’ – Application refused.
CRIMINAL LAW – Sentence – Murder – Whether judge gave insufficient weight to applicant’s age in setting non-parole period – Application refused.
---
| Appearances: | Counsel | Solicitors |
| For the Applicant | Mr D A Dann | Balmer and Associates Pty |
| For the Crown | Mr D A Trapnell SC | Mr C Hyland, Solicitor for Public Prosecutions |
ASHLEY JA:
Neave and Harper JJA, whose reasons for judgment I have had the advantage of reading in draft, have set out the general circumstances of this proceeding, the main arguments of counsel, relevant passages from the judge’s charge, and the grounds of appeal. I need not, in the circumstances, revisit those matters.
I agree with their Honours, for the reasons which follow, that the applications for leave to appeal against conviction and sentence should be refused.
Concerning grounds 4 and 8 on the conviction application, and the application for leave to appeal against sentence, I respectfully agree with what their Honours have said and have nothing to add.
Conviction application; Grounds 1 and 3
Grounds 1 and 3 are interrelated. But each of them requires discrete consideration. Ground 1 contends that the judge erred by not leaving common law self-defence to the jury, but only the defence in s 9AC of the Crimes Act1958. Ground 3 asserts that the judge misdirected the jury by directing it, in effect, that the starting point for consideration of ‘defensive homicide’ was a belief held by the applicant.
Ground 1
The main argument for the applicant upon ground 1 was that the defence created by s 9AC is more restrictive than common law self-defence. For that reason, the section should not be read to exclude common law self-defence except if there were plain words; and here there were none.Counsel acknowledged that there would be ambiguities whichever way s 9AC was read.
In my opinion s 9AC does operate to exclude common law self-defence in the case of murder. That is so for these reasons, which focus upon the words of the statute.
First, it is too simplistic to say that the statutory defence is more restrictive than the common law defence. In some ways, it is more restrictive.…
Continue reading Babic v The Queen
Sign in free to access the full text
- AGLC
- Babic v The Queen [2010] VSCA 198
- Case
- [2010] VSCA 198
- Decision Date
CaseChat Overview and Summary
The court held that the purpose of Subdivision 1AA of the Crimes Act 1958 was to replace existing common law defences to homicide, including self-defence, with statutory defences. The headings of the Division and sections within Subdivision 1AA supported this view, indicating that common law defences no longer applied. The court further found that there was no ambiguity as to the purpose of the legislation, and the presumption that Parliament could not have intended to disadvantage an accused was rebutted. The court concluded that self-defence had indeed been codified in sections 9AB to 9AH and 9AJ, rather than abolished. The jury directions were found to be correct, and the trial judge did not err in his references to an "imminent threat" or in addressing the issue of intoxication.
In light of the above, the court dismissed the application for leave to appeal against both the conviction and the sentence. The reasoning provided by the court was that the statutory framework introduced by the Crimes (Homicide) Act 2005 had effectively replaced the common law defences, and there was no error in the trial judge's handling of the case. Therefore, Babic's conviction and sentence for murder were upheld.
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
Full text does not contain this section.
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
Full text does not contain this section.