SUPREME COURT OF SOUTH AUSTRALIA
(Court of Criminal Appeal)
DUCAJ v THE QUEEN
[2019] SASCFC 152
Judgment of The Court of Criminal Appeal
(The Honourable Chief Justice Kourakis, The Honourable Justice Kelly, The Honourable Justice Peek, The Honourable Justice Stanley and The Honourable Justice Nicholson)
17 December 2019
CRIMINAL LAW - APPEAL AND NEW TRIAL - PARTICULAR GROUNDS OF APPEAL - MISDIRECTION AND NON-DIRECTION
CRIMINAL LAW - PARTICULAR OFFENCES - OFFENCES AGAINST THE PERSON
This is an appeal against conviction. The appellant was found guilty of the charge of aggravated creating a likelihood of harm contrary to s 29(3) of the Criminal Law Consolidation Act 1935 (SA) (CLCA).
Two police officers attended an address based on information that there might be cannabis growing on the premises. No answer was received when the officers knocked on the door. The appellant, from the rear of the premises, informed the officers that he was a cleaner and he would go inside to obtain identification. One of the officers, Constable Walker, positioned himself near some locked gates located in the middle of the driveway. The other officer, Constable Leahy, remained at the rear of the premises. She observed the appellant emerging from a hole on the roof. The appellant then entered a van parked on the premises. The trial judge found that the accused drove the van into, and over, the gate, and only narrowly missed colliding with Constable Walker as he took evasive action. Her Honour also found that the appellant committed the offence knowing the officer was acting in the course of his duties, thereby proving the aggravating feature of the offence.
There are two grounds of appeal. They are that the trial judge misdirected herself as to the elements of the offence of aggravated creating a likelihood of harm in that she held that proof of reckless indifference for the purpose of s 29(3)(b) only required the prosecution to establish that the applicant was aware of a substantial risk of harm and decided to engage in the relevant conduct nevertheless; and that the trial judge erred in holding that on the facts as found the offence was proved.
Held per Stanley J (Kourakis CJ, Kelly, Peek, and Nicholson JJ agreeing), dismissing the appeal on ground 1:
1. There has been no error demonstrated in the trial judge’s finding that a contravention of s 29(3) of the Criminal Law Consolidation Act 1935 (SA) was proved.
Held per Kourakis CJ (Kelly, Peek and Nicholson JJ agreeing), dismissing the appeal on ground 2:
1. The judge erred in law in directing herself that the element of reckless indifference involved engaging in conduct knowing that it exposed another to a substantial risk of harm. However, this failure cannot have affected the result because the judge correctly directed herself on the element of knowledge of the likelihood of harm in paragraph [15] of her Honour’s reasons.
Held per Stanley J, dismissing the appeal on ground 2:
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CaseChat Overview and Summary
The appeal raised two grounds: first, that the trial judge misdirected herself on the elements of the offence, specifically regarding the requirement of reckless indifference under s 29(3)(b), by holding that proof of this element only required the prosecution to establish the appellant's awareness of a substantial risk of harm and a decision to proceed with the conduct regardless; and second, that the trial judge erred in concluding that the offence was proven on the facts as found.
The Full Court dismissed the appeal. The majority found that the trial judge's implicit finding that the driving was objectively likely to cause harm, despite her Honour's more limited finding of a "real or substantial risk of harm," was sufficient. In the absence of evidence of any lawful excuse or adequate justification for the appellant's driving, the element of recklessness was necessarily made out on that finding.
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