Supreme Court of South Australia
(Court of Appeal: Criminal)
KINGSTON (A PSEUDONYM) v THE QUEEN; MAXWELL (A PSEUDONYM) v THE QUEEN
[2022] SASCA 90
Judgment of the Court of Appeal
(The Honourable Chief Justice Kourakis, the Honourable Justice Lovell and the Honourable Justice David)
1 September 2022
APPEAL AND NEW TRIAL - PROCEDURE - SOUTH AUSTRALIA
APPEAL AND NEW TRIAL - APPEAL - GENERAL PRINCIPLES - RIGHT OF APPEAL - WHEN APPEAL LIES - ERROR OF LAW
CRIMINAL LAW - PARTICULAR OFFENCES - DRUG OFFENCES - DEALING AND DISTRIBUTION OF DRUGS - TRAFFICKING OR SALE AND SUPPLY
CRIMINAL LAW - APPEAL AND NEW TRIAL - MISCARRIAGE OF JUSTICE - TESTS - WHETHER JURY WOULD HAVE RETURNED SAME VERDICT - MISDIRECTION AND NON-DIRECTION
CRIMINAL LAW - EVIDENCE - PROPENSITY, TENDENCY AND CO-INCIDENCE - ADMISSIBILITY AND RELEVANCY - PROPENSITY EVIDENCE
This is an appeal against conviction by two applicants who were jointly charged with attempting to traffic a large commercial quantity of a controlled substance, butanediol. Butanediol is a controlled substance in South Australia but its importation as an industrial chemical agent is not prohibited by any law of the Commonwealth.
At some point prior to 21 December 2018, an order was placed with a Chinese company in Shanghai for the purchase of 200 kilograms of the substance in a fictitious name. The applicants were charged after the butanediol was intercepted by police, who re-filled the containers with water, and then tracked the delivery to an address associated with the applicants.
The evidence led at trial was circumstantial, with no evidence of how the shipment of butanediol was ordered, its purchase price or how payment was made. The circumstantial evidence linking the applicants to the intercepted butanediol included: telephone calls to and between phone numbers associated with the applicants, the physical movements of the applicants at the time of the delivery of the butanediol, other purchases of butanediol circumstantially connected to the applicants and the applicants’ relational connection to each other and others involved in the delivery of the butanediol.
The applicants raise the following issues on appeal:
1. Whether the trial Judge erred in finding a case to answer, or in the alternative, not leaving to the jury the question of whether the drug was mixed or pure (Ground 1);
2. Whether the trial Judge erred in leaving ‘recklessness’ as a basis for liability on a charge of attempted trafficking (Ground 2);
3. Whether the trial miscarried after comments were made in the presence of the jury by a member of the gallery (Ground 3);
4. Whether the trial Judge erred by not directing the jury not to conduct their own enquiries outside of the court room (Ground 4); and
5. Whether the learned trial Judge erred by admitting evidence of previous purchases of 1,4‑Butanediol for propensity purposes in the trial (Ground 5).
Held, per Kourakis CJ, granting permission to appeal on Grounds 3, 4 and 5, allowing the appeal against conviction of each applicant and ordering a retrial on a…
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- Case
- [2022] SASCA 90
- Decision Date
CaseChat Overview and Summary
The court was required to determine whether the trial judge was correct in ruling that the butanediol seized, which was of high purity (approximately 95%), constituted a "mixture" as defined by the regulations, or if it was in its "pure" form. The distinction was critical because the regulations prescribe a large commercial quantity for butanediol in its mixed form, but not for its pure form. If the butanediol was pure, the applicants could only have been convicted of the lesser offence of attempted trafficking.
The court reasoned that the evidence did not establish that the butanediol was a mixture. While it contained minor impurities consistent with manufacturing and degradation, it was not otherwise adulterated. The trial judge's direction to the jury on the premise that it was a mixture, without leaving the factual question of its purity to the jury, constituted an error of law. Consequently, the court allowed the appeal, quashed the convictions for trafficking a large commercial quantity, and substituted verdicts of guilty for attempted trafficking in butanediol.
Orders
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Background
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Evidence
Evidence Before The Court
Decision
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Ratio Decidendi
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