SUPREME COURT OF SOUTH AUSTRALIA
(Full Court: Criminal)
LESTER v POLICE
[2013] SASCFC 123
Judgment of The Full Court
(The Honourable Chief Justice Kourakis, The Honourable Justice Peek and The Honourable Justice Stanley)
21 November 2013
CRIMINAL LAW - PARTICULAR OFFENCES - DRIVING OFFENCES
TRAFFIC LAW - OFFENCES - PARTICULAR OFFENCES - ALCOHOL AND DRUG RELATED OFFENCES
TRAFFIC LAW - OFFENCES - PARTICULAR OFFENCES - ALCOHOL AND DRUG RELATED OFFENCES - SOUTH AUSTRALIA - TESTING AND ANALYSIS PROCEDURE - BREATH TEST AND ANALYSIS
STATUTES - ACTS OF PARLIAMENT - INTERPRETATION - GENERAL APPROACHES TO INTERPRETATION - PURPOSIVE APPROACH
STATUTES - ACTS OF PARLIAMENT - INTERPRETATION - GENERAL APPROACHES TO INTERPRETATION - MISCHIEF TO BE REMEDIED AND PREVIOUS STATE OF LAW
STATUTES - ACTS OF PARLIAMENT - INTERPRETATION - GENERAL APPROACHES TO INTERPRETATION - LEGISLATIVE HISTORY OF ACT
The appellant was charged on Complaint with refusing to comply with all reasonable directions of a member of the police force to submit to an alcotest, contrary to s 47E(3), Road Traffic Act 1961. The appellant was stopped while driving by Constables Gitsham and Hawyes for the purpose of administering a random breath test. Gitsham pointed the straw attached to an alcometer at the appellant's lips and directed him to provide a breath sample. The appellant refused and re-entered his vehicle and closed the door. Before he could lock the door, Hawyes gained entry and prevented the appellant taking a drink from a flask. The appellant was then told he was under arrest. He appeared to the police to be feigning unconsciousness and was taken to the Royal Adelaide Hospital. The examining doctor opined he was feigning unconsciousness. Gitsham then proceeded to read to the appellant the prescribed oral advice required by s 47E(4)(ab) and gave him a final opportunity to submit to an alcotest. The appellant made no response and Gitsham took that as a refusal. It appears that Gitsham did not then have the alcometer with him.
At trial, the Magistrate dismissed the Complaint. He found that Gitsham had informed the appellant at the roadside that he was required to submit to an alcotest and had given a specific and reasonable direction to the appellant; this engaged the requirement that the appellant be given an opportunity to comply with that direction after having received the prescribed oral advice. The Magistrate found that the s 47E(4)(ab) obligations were not discharged as neither Gitsham nor another police officer in the immediate vicinity had an alcometer in their possession at the time the prescribed oral advice was given at the Royal Adelaide Hospital.
On appeal to the Supreme Court, the single Judge allowed the appeal and set aside the dismissal. The Judge held that the s 47E(4)(ab) obligations were never engaged as the roadside directions amounted only to a preliminary statement to the appellant that he was required to submit to an alcotest, and a specific direction to submit to that alcotest was never given, having been frustrated by the behaviour of the appellant;…
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- AGLC
- Lester v Police [2013] SASCFC 123
- Case
- [2013] SASCFC 123
- Decision Date
CaseChat Overview and Summary
The court was required to determine several legal issues. These included whether the police had the power to give preliminary directions to a motorist for the purpose of conducting an alcotest, and whether non-compliance with such directions constituted an offence. The court also had to consider whether the police had sufficiently informed the appellant of the requirement to submit to an alcotest, and whether the directions given to provide a breath sample were valid and reasonable. Furthermore, the court needed to assess the significance of the appellant's behaviour, including feigning unconsciousness, on the police's obligations. Finally, the court had to interpret the requirements of section 47E(4)(ab) of the Act, particularly concerning the possession of approved apparatus when discharging obligations under that section and the necessity of providing prescribed oral advice.
The Supreme Court, in dismissing the appeal, reasoned that police possess the power to give preliminary directions to motorists to facilitate an alcotest, and non-compliance with subsequent lawful directions constitutes an offence. The court found that the police had adequately informed the appellant of the requirement to submit to an alcotest and that the direction to provide a breath sample was valid and sufficiently specific. The appellant's refusal to comply with the direction to exhale into the alcometer enlivened the obligations under section 47E(4)(ab). The court held that the appellant's disruptive behaviour, including feigning unconsciousness, justified the police in taking him to the hospital and providing the prescribed oral advice there. Crucially, the court determined that while an approved apparatus must be possessed when making the initial requirement for an alcotest, this is not a statutory requirement when discharging the obligations under section 47E(4)(ab). The court emphasised the importance of providing clear advice regarding the consequences of non-compliance, but noted that this obligation does not apply where a driver's positive action frustrates compliance. The court concluded that the police had discharged their obligations under section 47E(4)(ab) at the hospital, and the appellant had failed to comply, leading to the conviction.
Orders
Orders of the court
Held (Peek J, Kourakis CJ and Stanley J agreeing, dismissing the appeal):
The Judge was correct in allowing the appeal for reasons other than as expressed by his Honour. [42], [44], [90]
(1) Under s 47E(2), police have power to give certain preliminary directions to a motorist for the purpose of bringing about the situation where police are in a position to make a requirement under s 47E that the motorist undergo an alcotest. Once such a requirement is made, s 47E(3) empowers police to give reasonable directions to a motorist for that purpose. Non-compliance with such directions is an offence under s 47E(3). [48]-[58]
(2) The police here sufficiently informed the appellant that he was required to submit to an alcotest. [59]-[66], [67]-[71], [74]-[76]
(3) The direction to provide a breath sample given at the roadside was a valid and reasonable direction given under s 47E(3) in that:
(i) by directing the appellant to provide a breath sample by blowing into the proffered straw attached to the alcometer, Gitsham had given directions associated with the performance of the physical acts required by the appellant in order for the test to be carried out. [67]-[71]
(ii) the direction was sufficiently specific as to how the exhalation should be performed. [27], [74]-[76]
(4) It is clear that the appellant elected to refuse to comply with the direction to exhale into the alcotest. That refusal to exhale into the alcotest enlivened the s 47E(4)(ab) obligations. [28]-[29], [77]-[78], [89]
(5) The fact that the police could have given the prescribed oral advice to the appellant at the scene, while he was feigning unconsciousness, did not in the particular circumstances of the case disentitle the police from later giving that advice to the appellant at the Royal Adelaide Hospital. The appellant's behaviour produced a disruptive and confusing situation and the police acted reasonably in taking him to the Emergency Department where they received medical advice that the appellant was feigning unconsciousness and in determining to then give the prescribed oral advice. [30]-[31]
(6) While a police officer must have possession of the relevant apparatus when making the original direction that a motorist submit to an alcotest, there is no such statutory requirement when discharging the s 47E(4)(ab) obligations. [34]-[42]
(7) The interpretation of s 47E(4)(ab) is governed by the following considerations:
(i) The Road Traffic Act 1961 recognises that it is both desirable and important that drivers who may be unenthusiastic about complying with a peremptory direction given by police when they may have done nothing wrong, and may be ignorant of the precise consequences of failing to do so, should be given: very clear advice as to those consequences; a final chance to calmly consider their position; and a final opportunity to comply with the direction. [83]
(ii) The obligation to give the prescribed oral advice does not apply to refusals to comply with a direction where positive action is taken by a driver which produces irreversible consequences frustrating compliance with the direction. [84]
(iii) Where s 47E(3) has been engaged, the mandatory penalties (including licence disqualification) apply no matter what direction is disobeyed and it is equally important in relation to all directions that the driver be made aware of the consequences of disobedience. [85]
(8) Here, the s 47E(4)(ab) obligations were discharged by Gitsham at the Royal Adelaide Hospital; the appellant eschewed the opportunity to repent. The Judge was correct to set aside the dismissal and convict the appellant. [34]-[42], [78], [89]
Background
Background to the litigation
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Evidence
Evidence Before The Court
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
Established by: KOURAKIS CJ, PEEK J,
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