SUPREME COURT OF SOUTH AUSTRALIA
(Court of Criminal Appeal)
R v DONJERKOVIC
[2012] SASCFC 2
Judgment of The Court of Criminal Appeal
(The Honourable Chief Justice Doyle, The Honourable Justice Vanstone and The Honourable Justice Blue)
11 January 2012
CRIMINAL LAW - PARTICULAR OFFENCES - PROPERTY OFFENCES - OTHER FRAUDS AND IMPOSITIONS - OBTAINING PROPERTY BY DECEPTION
APPEAL AND NEW TRIAL - NEW TRIAL - IN GENERAL AND PARTICULAR GROUNDS - PARTICULAR GROUNDS - MISDIRECTION OR NON-DIRECTION - DIRECTIONS AS TO PARTICULAR MATTERS
The appellant was found guilty by a jury on six counts of deception, contrary to the Criminal Law Consolidation Act 1935 (SA) s 139 - the appellant appealed against convictions - the appellant misrepresented to the victim to transfer monies into an account for the purposes of purchasing and developing residential property as a joint venture - when the monies were transferred into the account, the appellant withdrew, or caused to be withdrawn, money from the account for purposes other than that of the joint venture to the detriment of the victim.
The issue on appeal was whether the deception alleged by the prosecution, and found to be proved by the jury, caused the detriment to the victim as alleged by the prosecution - this required the Court to consider whether in the circumstances it was open to the jury to find that the dishonest deception caused a detriment as alleged by the proscution - whether the Judge's directions on the question of causation were adequate.
Held: As a matter of commonsense, and bearing in mind that the question of causation arises for the purpose of attributing criminal responsibility, it was open to the jury to find as a matter of fact that the appellant's deception caused the detriment to the victim when the funds were transferred from the joint venture account - the Judge's directions on causation were adequate in the circumstances.
Appeal dismissed.
Criminal Law Consolidation Act 1935 (SA) s 130, s 139; Criminal Law Consolidation (Offences of Dishonesty) Act 2002 (SA) s 4, referred to.
Royall v The Queen (1990) 172 CLR 378; Campbell v The Queen [1981] WAR 286, discussed.
R v DONJERKOVIC
[2012] SASCFC 2Court of Criminal appeal: Doyle CJ, Vanstone and Blue JJ
DOYLE CJ: Mr Donjerkovic was found guilty by a jury on six counts of the offence of deception, contrary to s 139 of the Criminal Law Consolidation Act 1935 (SA) (the CLCA). All counts were inter-related. Mr Donjerkovic appeals against the convictions. Permission to appeal was granted by a single Judge of this Court.
The issue on appeal is whether the deception alleged by the prosecution, and found to be proved by the jury, caused the detriment relied upon by the prosecution to complete the offence. Mr Heffernan submits that as a matter of law it was not open to the jury to find that the detriment was caused by the deception. He submits that the Judge should have directed the jury to acquit on…
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CaseChat Overview and Summary
The central legal issue before the Court was whether the jury’s finding that the appellant’s deception caused the victim’s detriment was open to them on the evidence. This required the Court to consider the adequacy of the trial judge's directions to the jury on the question of causation, specifically whether the deception was operative at the time of the withdrawals from the joint venture account and whether it led to the victim’s loss.
The Court reasoned that the appellant had deceived Mr Doyle by representing that funds transferred into a joint venture account would be used solely for the improvement and sale of a specific property. In reality, the appellant had no such arrangement and intended to use the funds for his own purposes. The Court found that the appellant’s continued misrepresentations, even after the initial transfer of funds, fostered Mr Doyle’s belief and caused him to leave the money at the appellant’s disposal. Applying a common-sense approach to causation for the purposes of criminal responsibility, the Court concluded that the appellant’s deceit was the means by which he gained access to the funds and was therefore the cause of the detriment suffered by Mr Doyle. The Court held that the trial judge’s directions on causation, while brief, were adequate, as they directed the jury to consider whether the deception was still operative at the time of each withdrawal and to give the word "caused" a broad meaning.
The appeal was dismissed, with the Court finding that the jury’s verdict was open to them on the evidence and that no miscarriage of justice had occurred.
Orders
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Background to the litigation
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Evidence Before The Court
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Ratio Decidendi
Legal Principle Established
The other thing that must always be borne in mind is that the issue is whether causation is made out for the purposes of attributing criminal responsibility for the relevant consequence.Consideration of the issues on appeal I do not accept Mr Heffernan’s submission. I approach the issue using commonsense, doing my best to avoid assuming the answer to the question that arises, and doing my best to avoid using the formula “commonsense” as a substitute for reasoning and reflection. Mr Donjerkovic deceived Mr Doyle about the manner in which Mr Donjerkovic would use money transferred by Mr Doyle to the joint venture account. He told Mr Doyle, knowing it to be false, that he would use the money in the joint venture account improving the property at Marryatville. The deception was intended to cause Mr Doyle to make the money available to Mr Donjerkovic, so that he could use it dishonestly and contrary to the joint venture arrangement. The deceit practised by Mr Donjerkovic persuaded Mr Doyle to put the money at Mr Donjerkovic’s disposition. To my mind, as a matter of commonsense, and for the purpose of attributing criminal responsibility, it was appropriate to conclude that the deception was the cause of the later detriment. That the deceit was the means by which Mr Donjerkovic was able to draw on the funds in the joint venture account appears quite clearly from the circumstances of count six. Within three days of the second transfer of funds to the joint venture account, Mr Donjerkovic took the whole $55,000. The gap between the transfer of funds and the taking of money was greater in the cases of the first five counts, but in my opinion that is of no particular relevance. Moreover, the deception was continued after the first transfer. Mr Donjerkovic did not tell Mr Doyle that he had not made any agreement with the owner of the property. The circumstances indicate that had Mr Doyle known that, he would have taken steps to retrieve his money, or what was left of it, or to prevent its misuse. This is strongly supported by Mr Doyle’s suggestion on 5 December 2005 that as the funds had not been drawn on, he might return the funds to an account where the availability of the funds would save him interest. But in any event, it is clear that the initial deceit by Mr Donjerkovic continued to affect the mind of Mr Doyle, causing him to leave the funds in the joint venture account and at Mr Donjerkovic’s disposal. As a matter of commonsense, and bearing in mind that the question of causation arises for the purpose of attributing criminal responsibility, I am quite satisfied that it was open to the jury to find as a matter of fact that the deceit by Mr Donjerkovic caused the detriment that Mr Doyle suffered, when each of the six transfers of funds from the joint venture account was made. Indeed, in my opinion the finding that the jury made was almost inevitable. To say that is not to deny that the immediate cause of the detriment was, as the Judge pointed out to the jury, the act of Mr Donjerkovic, or Mrs Donjerkovic at his direction, in transferring or withdrawing the funds. But this was nothing more than the consummation of a deceit practised by Mr Donjerkovic on Mr Doyle. It is what Mr Donjerkovic always intended to do, knowing that it was dishonest, to obtain money for his own purposes.