Obian v The King

Case [2023] VSCA 18


SUPREME COURT OF VICTORIA

COURT OF APPEAL

S EAPCR 2021 0164
SAER OBIAN Applicant
v
THE KING Respondent

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JUDGES: PRIEST, NIALL and MACAULAY JJA
WHERE HELD: Melbourne
DATE OF HEARING: 14 October 2022 
DATE OF JUDGMENT: 16 February 2023
MEDIUM NEUTRAL CITATION: [2023] VSCA 18
JUDGMENT APPEALED FROM: [2020] VCC 915 (Judge Trapnell)

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CRIMINAL LAW – Appeal – Conviction – Applicant convicted of three charges of trafficking in a drug of dependence, 1,4-butanediol (‘1,4-BD’) – Applicant gave evidence in his defence – Prosecution permitted to re-open case and introduce rebuttal evidence before cross-examination of the applicant completed – Admission of rebuttal evidence did not amount to a miscarriage of justice – Prosecution could not have reasonably foreseen evidence given by applicant – Extension of time in which to apply for leave to appeal granted, but leave to appeal refused.

CRIMINAL LAW – Appeal – Conviction – Trial judge refused defence counsel leave to confer with applicant during cross-examination – Whether refusal was an irregularity in the trial resulting in a substantial miscarriage of justice – Extension of time in which to apply for leave to appeal granted, but leave to appeal refused.

CRIMINAL LAW – Appeal – Sentence – Three charges of trafficking in a drug of dependence in not less than a commercial quantity – Quantities of 1,4-BD between 400 and 8,000 times commercial quantity threshold – Maximum penalty 25 years’ imprisonment – Applicant directing mind of sophisticated operation with sole motivation for financial gain – Total effective sentence 17 years and 10 months’ imprisonment with non-parole period of 12 years and 10 months – Whether sentence manifestly excessive – Mitigating factors of youth, no prior convictions, delay and COVID-19 burden of imprisonment – Totality – Co-offender who played less substantial role and had benefit of other mitigatory factors sentenced to 8 years’ imprisonment – Total effective sentence not wholly outside range open to trial judge – Sentence did not breach principle of parity – Extension of time in which to apply for leave to appeal sentence refused.

Criminal Procedure Act 2009, s 233; Shaw v The Queen (1952) 85 CLR 365; Killick v The Queen (1981) 147 CLR 565; Lawrence v The Queen (1981) 38 ALR 1; R v Chin (1985) 157 CLR 671; Alfarsi (a pseudonym) v The Queen [2021] VSCA 283, considered.

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Counsel

Applicant: Mr CT Carr SC with Ms CA Boston
Respondent: Mr CB Boyce KC with Mr GB Buchhorn

Solicitors

Applicant: Milides Lawyers
Respondent: Ms A Hogan, Solicitor for Public Prosecutions

PRIEST JA:

Introduction

  1. After a trial of almost five weeks’ duration, on 24 September 2019 a jury in the County Court found the applicant guilty of three charges of trafficking in a drug of dependence, 1,4-butanediol (‘1,4-BD’), in not less than a commercial quantity.[1] He was subsequently imprisoned.[2]

    [1]Drugs, Poisons and Controlled Substances Act 1981, s 71AA. The maximum penalty is 25 years’ imprisonment.

    [2]Following a plea in mitigation, on…

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Obian v The King [2023] VSCA 18
Case
[2023] VSCA 18
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CaseChat Overview and Summary

Obian was convicted of three charges of trafficking in a drug of dependence, specifically 1,4-butanediol (‘1,4-BD’). Obian appealed his conviction and sentence, asserting that the trial judge erred in allowing the prosecution to introduce rebuttal evidence before cross-examination of him was completed, in refusing to allow his counsel to confer with him during cross-examination, and in imposing a sentence that was manifestly excessive. The central legal issues were whether the introduction of rebuttal evidence and refusal to allow counsel to confer with the applicant constituted irregularities that resulted in a substantial miscarriage of justice, and whether the sentence imposed was manifestly excessive.

The court found that the trial judge did not err in permitting the introduction of rebuttal evidence under s 233 of the Criminal Procedure Act 2009, as the evidence given by the applicant could not reasonably have been foreseen by the prosecution. The court also held that the refusal to allow counsel to confer with the applicant during cross-examination did not result in a substantial miscarriage of justice, as the applicant had not demonstrated how the refusal had prejudiced him. Regarding the sentence, the court concluded that the total effective sentence of 17 years and 10 months’ imprisonment with a non-parole period of 12 years and 10 months was not manifestly excessive, considering the totality of the circumstances, including the quantities of 1,4-BD involved, the applicant’s role in a sophisticated operation motivated by financial gain, and the mitigating factors of youth, no prior convictions, delay, and the COVID-19 burden of imprisonment.

The court granted an extension of time in which to apply for leave to appeal the conviction and refusal to allow counsel to confer with the applicant but refused leave to appeal. The court also refused an extension of time to apply for leave to appeal the sentence.

Orders

Orders of the court

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Background

Background to the litigation

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Evidence

Evidence Before The Court

The application to re-open the prosecution case to call ‘rebuttal’ evidence was governed by s 233 of the Criminal Procedure Act 2009 (‘CPA’), which provides:233 Introduction of evidence not previously disclosed …(2) If, after the close of the prosecution case, the accused gives evidence which could not reasonably have been foreseen by the prosecution having regard to — (a) the response of the accused to the summary of the prosecution opening; and (b) the response of the accused to the notice of pre-trial admissions— as served on the prosecution and filed in court, the trial judge may allow the prosecutor to call evidence in reply. (3) Nothing in this section limits any other power of the trial judge to allow the prosecutor to call evidence after the prosecutor has closed the prosecution case. Plainly, s 233(2) confers a discretion on a trial judge to allow the prosecutor to call evidence ‘in reply’. No matter what else might be said of its parameters, it is clear that the discretion may only be exercised in a manner adverse to the accused if he or she gives evidence which could not reasonably have been foreseen having regard to, first, the accused’s response to the summary of the prosecution opening; and, secondly, the response of the accused to the notice of pre-trial admissions. The need for the accused to provide the relevant responses arises from the provisions of ss 182 and 183 of the CPA. Section 182(1) requires the DPP, at least 28 days before the listed trial date, to serve on the accused and file in court a summary of the prosecution opening and a notice of pre-trial admissions. Sub-section (2) requires the summary of prosecution opening to outline the manner in which the prosecution will put the case against the accused, and the acts, facts, matters and circumstances being relied on to support a finding of guilt. By sub-section (3), the notice of pre-trial admissions must identify the statements of the witnesses whose evidence, in the opinion of the DPP, ought to be admitted as evidence without further proof, including evidence that is directed solely to formal matters In turn, s 183(1) requires the accused to serve on the prosecution both a copy of the response of the accused to the summary of the prosecution opening and a copy of the response of the accused to the notice of pre-trial admissions. By sub-section (2), the response of the accused to the summary of the prosecution opening ‘must identify the acts, facts, matters and circumstances with which issue is taken and the basis on which issue is taken’; and sub-section (3) provides that the response of the accused to the notice of pre‑trial admissions must indicate what evidence, as set out in the notice of pre-trial admissions, is agreed to be admitted as evidence without further proof and what evidence is in issue and, if issue is taken, the basis on which issue is taken. Further, the effect of s 184 is that, if the accused ‘intends to depart substantially at trial’ from the filed and served responses, he or she must so inform the court and the prosecution ‘in advance of the trial’; and ‘if the court so orders, must inform the court and the other party of the details of the proposed departure’.

Decision

Reasons for decision

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Ratio Decidendi

Legal Principle Established

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