SUPREME COURT OF SOUTH AUSTRALIA
(Court of Appeal: Criminal)
EMERY v THE QUEEN
[2021] SASCA 62
Judgment of the Court of Appeal
(The Honourable President Kelly, the Honourable Justice Doyle and the Honourable Justice Bleby)
17 June 2021
CRIMINAL LAW - EVIDENCE - JUDICIAL DISCRETION TO ADMIT OR EXCLUDE EVIDENCE - EVIDENCE UNFAIR TO ADMIT OR IMPROPERLY OBTAINED
CRIMINAL LAW - PARTICULAR OFFENCES - DRUG OFFENCES - DEALING AND DISTRIBUTION OF DRUGS - TRAFFICKING OR SALE AND SUPPLY
Appeal against conviction.
The appellant was convicted following a trial by Judge alone of trafficking in a large commercial quantity of a controlled drug contrary to s 32(1) of the Controlled Substances Act 1984. The offending related to a search of the appellant’s vehicle in May 2019, during which a total of 1.95 kilograms of methylamphetamine was located.
Prior to the trial, the appellant made an application pursuant to r 49(1)(h) of the District Court Criminal Rules 2014, seeking to exclude evidence of the search and evidence of an inculpatory statement made by the appellant. The statement was made while the appellant was being searched by police at the commencement of his record of interview. Following a hearing, the Judge dismissed the application.
The appellant appeals against his conviction on two grounds. First, it was contended that the Judge erred in finding that the search of the vehicle was lawful, in circumstances where police could not have held a ‘reasonable suspicion’ pursuant to s 52(9) of the Controlled Substances Act 1984. Second, it was argued that the record of interview was obtained in circumstances where the police, as a result of pausing to complete a safety search of the appellant, failed to comply with the obligation to provide the appellant with all of his arrest rights as soon as reasonably practicable. In respect of both grounds, it was further argued that the unlawfully obtained evidence ought to be excluded in the exercise of the Judge’s discretion.
Held (by the Court), granting permission to appeal on both grounds and dismissing the appeal in respect of both grounds:
1. It was open to the Judge to conclude that the information held by the police officer on the date of the search was a sufficient basis to form the requisite suspicion required under s 52(9) of the Controlled Substances Act 1984. There was nothing unlawful about the search.
2. The delay in advising the appellant of his rights under s 79A(3) of the Summary Offences Act 1953 was minimal and the police should not be criticised for giving priority to the safety check.
3. No error has been demonstrated in the Judge’s decision not to exclude the evidence of the search and the record of interview.
Controlled Substances Act 1984 (SA) s 32(1), s 52(9); Summary Offences Act 1953 (SA) s 79A; District Court Criminal Rules 2014 (SA) r 49(1)(h), referred to.
R v Nguyen (2013) 117 SASR 432, applied.
R v Dam and Nguyen (2015) 123 SASR 511; R v Nguyen (2015)…
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CaseChat Overview and Summary
The primary legal issues before the Court of Appeal were whether the search of the appellant's vehicle was lawful under section 52 of the *Controlled Substances Act 1984* (SA), and whether the appellant's rights under section 79A(3) of the *Summary Offences Act 1953* (SA) were adequately afforded to him during the process of his arrest and interview. The court was also required to consider whether, even if the search or the interview process had some irregularity, the evidence should have been excluded in the exercise of judicial discretion due to unfairness or improper obtaining.
The Court of Appeal held that the police officer possessed sufficient information to form the requisite suspicion for the search under section 52 of the *Controlled Substances Act*, rendering the search lawful. Regarding the interview, the court found that any delay in advising the appellant of his full rights under section 79A(3) of the *Summary Offences Act* was minimal and justifiable given the priority placed on a safety check. The court concluded that no error had been demonstrated in the trial judge's decision not to exclude the evidence from the search and the record of interview, noting the strong public interest in prosecuting serious drug offending and the absence of reckless or malicious conduct by the police.
Permission to appeal was granted on both grounds, but the appeal itself was dismissed. The Court of Appeal upheld the trial judge's decision to admit the evidence.
Orders
Orders of the court
Held (by the Court), granting permission to appeal on both grounds and dismissing the appeal in respect of both grounds:
1. It was open to the Judge to conclude that the information held by the police officer on the date of the search was a sufficient basis to form the requisite suspicion required under s 52(9) of the Controlled Substances Act 1984. There was nothing unlawful about the search.
2. The delay in advising the appellant of his rights under s 79A(3) of the Summary Offences Act 1953 was minimal and the police should not be criticised for giving priority to the safety check.
3. No error has been demonstrated in the Judge’s decision not to exclude the evidence of the search and the record of interview.
Background
Background to the litigation
Evidence
Evidence Before The Court
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Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
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