Bolton (a pseudonym) v The Queen

Case [2021] VSCA 237


SUPREME COURT OF VICTORIA

COURT OF APPEAL

S EAPCR 2020 0152

CLYDE BOLTON (a pseudonym)[1] Applicant
v
THE QUEEN Respondent

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

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JUDGES: KYROU and KENNEDY JJA
WHERE HELD: MELBOURNE
DATE OF HEARING: 24 August 2021
DATE OF JUDGMENT: 31 August 2021
MEDIUM NEUTRAL CITATION: [2021] VSCA 237
JUDGMENT APPEALED FROM: [2019] VCC 1247 (Judge Gaynor)

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CRIMINAL LAW – Appeal – Conviction – Application for extension of time to file application for leave to appeal – Applicant convicted of 6 charges of incest, 1 charge of gross indecency with a child under 16 and 1 charge of indecent act with a child under 16 – Proposed ground of appeal that conviction on 1 incest charge unsafe and unsatisfactory because evidence did not establish penetration – Crown concession that proposed ground reasonably arguable – Common ground that, if conviction for incest set aside, conviction for attempted incest could be substituted without need for new trial – Delay of nearly 11 months in filing application for leave to appeal – Whether satisfactory explanation for delay – Public interest in finality of criminal proceedings – Public interest in removal of unsafe convictions – Extension of time and leave to appeal granted – Criminal Procedure Act 2009 s 277.

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APPEARANCES:

Counsel Solicitors
For the Applicant Mr R F Edney Stary Norton Halphen
For the Respondent Ms E Ruddle QC Ms A Hogan, Solicitor for Public Prosecutions

KYROU JA
KENNEDY JA:

Introduction and summary

  1. On 14 June 2019, following a jury trial before a County Court judge, the applicant was convicted of the offences set out in the table below.  On 9 August 2019, he was sentenced as set out in that table:[2]

Charge Offence Maximum Sentence Cumulation
1 Gross indecency with a child under 16 [Crimes Act 1958 s 50(1)] 2 years 6 months Nil
2 Incest [Crimes Act s 52(1)] 20 years 2 years 1 year
3 Incest [Crimes Act s 52(1)] 20 years 7 years Base
8 Incest [Crimes Act s 44(1)] 25 years 2 years 1 year
9 Incest [Crimes Act s 44(1)] 25 years 2 years 1 year
10 Incest [Crimes Act s 44(1)] 25 years 2 years 1 year
11 Indecent act with a child under 16 [Crimes Act s 47(1)] 10 years 6 months 3 months
12 Incest [Crimes Act s 44(1)] 25 years 2 years 1 year
Total effective sentence: 12 years and 3 months’ imprisonment
Non-parole period: 9 years and 6 months’ imprisonment
Pre-sentence declaration: 49 days
Other orders: Reporting period of life pursuant to s 34 of the Sex Offenders Registration Act 2004
  1. Incest charges 2 and 3 involved the applicant’s daughter (‘AB’), whilst incest charges 8, 9, 10 and 12 involved a…

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Bolton (a pseudonym) v The Queen [2021] VSCA 237
Case
[2021] VSCA 237
Decision Date

CaseChat Overview and Summary

The appellant, identified as Bolton, was convicted in a lower court on six charges of incest, one charge of gross indecency with a child under 16, and one charge of indecent act with a child under 16. This appeal centred on the applicant's request for an extension of time to file an application for leave to appeal, as well as the appeal itself. The primary legal issues were whether there was a satisfactory explanation for the delay in filing the application for leave to appeal, and whether the public interest favoured the grant of an extension of time and leave to appeal.

The court considered the delay of nearly 11 months in filing the application for leave to appeal and the competing public interests at stake. The court noted that Bolton proposed to appeal on the ground that his conviction on one of the incest charges was unsafe and unsatisfactory because the evidence did not establish penetration. The Crown conceded that this ground was reasonably arguable, and it was common ground that if the conviction for incest was set aside, a conviction for attempted incest could be substituted without the need for a new trial. The court held that the delay was not entirely inexcusable and there were mitigating factors, such as the applicant's change of legal representation and the complexity of the issues. Furthermore, the public interest favoured the removal of unsafe convictions and the finality of criminal proceedings was not significantly prejudiced by the delay.

The court granted the extension of time and leave to appeal under the Criminal Procedure Act 2009 s 277, allowing Bolton to proceed with his appeal against the conviction on one of the incest charges. This decision recognised the importance of addressing unsafe convictions while balancing the public interest in the finality of criminal proceedings.

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Background

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Decision

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Legal Principle Established

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