Michaels v The Queen

Michaels appealed his conviction for armed robbery to the High Court of Australia. The appeal concerned the admissibility of evidence obtained from the appellant following his arrest.

The central legal issue before the High Court was whether the trial judge erred in admitting evidence of a confession made by the appellant to police, despite the appellant having been unlawfully detained at the time of the confession. The court was required to consider the application of the exclusionary rule in relation to evidence obtained in breach of a person's legal rights.

The High Court held that the admission of the confession was an error. Brennan, Dawson and McHugh JJ reasoned that while the court has a discretion to admit evidence obtained in breach of law, that discretion should not be exercised in favour of admitting evidence where its admission would be unfair to the accused. In this instance, the unlawful detention rendered the confession unfair to the appellant, and therefore it should have been excluded. The appeal was allowed, and the conviction was quashed.