SUPREME COURT OF SOUTH AUSTRALIA
(Court of Appeal: Criminal)
KIRKLAND v THE QUEEN
[2021] SASCA 14
Judgment of the Court of Appeal
(The Honourable President Kelly, the Honourable Justice Lovell and the Honourable Justice Bleby)
25 March 2021
CRIMINAL LAW - APPEAL AND NEW TRIAL - MISCARRIAGE OF JUSTICE - WHAT CONSTITUTES
CRIMINAL LAW - APPEAL AND NEW TRIAL - PARTICULAR GROUNDS OF APPEAL - MISDIRECTION AND NON-DIRECTION
APPEAL AND NEW TRIAL - APPEAL - GENERAL PRINCIPLES - RIGHT OF APPEAL - WHEN APPEAL LIES - ERROR OF LAW - PARTICULAR CASES INVOLVING ERROR OF LAW - FAILURE TO GIVE REASONS FOR DECISION - ADEQUACY OF REASONS
CRIMINAL LAW - APPEAL AND NEW TRIAL - VERDICT UNREASONABLE OR INSUPPORTABLE HAVING REGARD TO EVIDENCE
Following a trial by judge alone, the appellant was found guilty of one count of maintaining an unlawful sexual relationship with a child. The complainant was the de facto step-daughter of the appellant. The appellant offended against the complainant on three occasions when she was approximately 13 years old. On each occasion, he sucked her breasts and touched her vagina and breasts. On the third occasion, he tied her up before assaulting her.
The appellant appeals against his conviction on the basis that the fair trial of the appellant miscarried due to the use made by the Trial Judge of evidence of the complainant’s mother, as well as the failure of the Trial Judge to provide adequate reasons. He further contends that the verdict was unsafe and unsatisfactory.
Held, per Lovell JA (Bleby JA agreeing) granting permission to appeal in respect of ground 3, allowing the appeal in respect of grounds 3 and 4, quashing the conviction and remitting the matter for retrial:
1. The Trial Judge’s use of the complainant’s mother’s evidence in the circumstances constituted a breach of procedural fairness leading to a miscarriage of justice.
Held, per Kelly P (dissenting) dismissing the appeal in respect of grounds 3, 4 and 5:
1. The Trial Judge’s remarks do not reveal any propensity reasoning or any error.
Criminal Law Consolidation Act 1935 (SA) s 50(1); Criminal Procedure Act 1921 (SA) s 158; Evidence Act 1929 (SA) ss 12A, 13A(12), 13BA(6), 34CB, 34P; Juries Act 1927 (SA) s 7, referred to.
R v T, WA (2014) 118 SASR 382; R v Haak (2012) 112 SASR 315; R v W, CT [2019] SASCFC 18; JGS v The Queen [2020] SASCFC 48 ; Nicholls v The Queen (2005) 219 CLR 196; Baini v R (2012) 246 CLR 469; R v ADW (2002) 84 SASR 178; Nudd v The Queen (2006) 80 ALJR 614; Douglass v The Queen (2012) 290 ALR 699; Whisprun Pty Ltd v Dixon (2003) 200 ALR 447; Macks v Viscariello (2017) 130 SASR 1; R v Becirovic [2017] SASCFC 156; TKWJ v R (2002) 212 CLR 124, applied.
R v Turney (1990) 52 SASR 438; R v Sierke [2011] SASCFC 53; Cawthray…
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CaseChat Overview and Summary
The legal issues before the Court of Criminal Appeal included whether the trial judge erred in his evaluation of the complainant's reliability as distinct from her credibility, and whether the trial judge's reasons for his findings were adequate. Further grounds of appeal concerned the use of evidence from the complainant's mother regarding sexual restraints, with the appellant arguing that this evidence was improperly used to corroborate the complainant's account or for a propensity purpose that was not open to the judge. The appellant contended that the trial miscarried due to the judge's use of this evidence in a manner not foreshadowed by the prosecution or submissions.
Kelly P found that the trial judge's reasons, though brief, were adequate given the short nature of the trial and the single issue in dispute, and would have dismissed the appeal on all grounds. However, Lovell JA disagreed with Kelly P's conclusions on grounds 3 and 4, finding that the trial judge's use of the complainant's mother's evidence regarding restraints was problematic. Lovell JA considered that the combination of grounds 3 and 4 complained that the trial was unfair because the judge used the evidence in a way that was not opened by the prosecutor and was not the subject of submissions by counsel, implying the evidence was inadmissible if its sole purpose was to show propensity.
Lovell JA concluded that there was a breach of procedural fairness leading to a miscarriage of justice, and therefore would have allowed the appeal on grounds 3 and 4. The specific outcome regarding the appeal's allowance or dismissal was not fully detailed in the provided text, as Lovell JA indicated disagreement with Kelly P on certain grounds, while agreeing on others, and stated it was unnecessary to decide all grounds.
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