SUPREME COURT OF SOUTH AUSTRALIA
(Court of Criminal Appeal)
R v DRUMMOND (NO 2)
[2015] SASCFC 82
Judgment of The Court of Criminal Appeal
(The Honourable Justice Gray, The Honourable Justice Peek and The Honourable Justice Blue)
5 June 2015
CRIMINAL LAW - APPEAL AND NEW TRIAL - MISCARRIAGE OF JUSTICE - GENERALLY
CRIMINAL LAW - APPEAL AND NEW TRIAL - PARTICULAR GROUNDS OF APPEAL - FRESH EVIDENCE - AVAILABILITY AT TRIAL, MATERIALITY AND COGENCY - GENERALLY
CRIMINAL LAW - APPEAL AND NEW TRIAL - PROCEDURE - POWERS OF COURT ON APPEAL - POWER TO ORDER NEW TRIAL OR QUASH CONVICTION AND DIRECT ENTRY OF VERDICT OF ACQUITTAL
Second appeal against conviction.
The applicant was convicted by a jury of attempted kidnapping. The complainant was walking on the footpath of Prospect Road when she noticed a white station wagon drive slowly past her. She recorded its registration number because she considered that the driver was acting suspiciously. She saw a man alight from a white station wagon which she believed was the same vehicle. A stranger approached her from behind, grabbed the top of her arm and told her to get in the car. There was a tussle, in the course of which the stranger pulled the complainant backwards, the complainant pushed him backwards by the chest and arm and punched him two or three times. The man returned to his car.
The major issue at trial was the identity of the assailant but it was not conceded that the alleged events had occurred. The complainant was unable to identify the applicant as her assailant, choosing a different person in a photopak identification procedure. She described the clothes that her assailant was wearing, which did not match the clothes that the defendant was wearing. The defendant gave evidence at trial that he was driving along Prospect Road at about the time of the incident but he did not stop, and he was not the assailant.
The police recovered the tops that the complainant and defendant were wearing at the relevant time and they were tested for DNA. The prosecution called a forensic scientist, Ms Mitchell, to give evidence concerning the DNA results. She gave evidence that sample swabs from the applicant’s clothing indicated that two persons had contributed to the DNA result with the complainant being positively excluded as being one of those contributors; she also gave evidence that sample swabs from the complainant’s clothing indicated that at least three persons had contributed to the DNA result with the applicant being positively excluded as being one of those contributors.
Ms Mitchell gave evidence that DNA was not always found after contact had occurred. She said that studies at Forensic Science SA had shown that only 10 per cent of samples provided any useful information or usable DNA. This evidence was the subject of cross-examination.
The defendant was found guilty by a jury and his first appeal to the Full Court was dismissed. An application for special leave was refused.
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CaseChat Overview and Summary
The court was required to determine whether the new evidence was "fresh and compelling" and if its consideration was "in the interests of justice." Subsequently, the court had to assess whether it was reasonably arguable that a substantial miscarriage of justice had occurred, justifying the grant of permission to appeal, and if such a miscarriage had indeed occurred, warranting the allowance of the appeal. The court also considered the definition of a "substantial miscarriage of justice" in the context of irregularities in or connected with a trial, including the wrongful admission or rejection of evidence, or misleading evidence.
The court reasoned that the very reasons for the new evidence being fresh and compelling rendered it in the interests of justice to consider it, thereby satisfying the initial threshold criteria under subsection 353A(1). The court then applied the principles established in cases such as *R v Keogh (No 2)* and *Baini v The Queen*, which define a substantial miscarriage of justice. This can occur when there has been an irregularity in the trial, such as the wrongful admission or rejection of evidence, or misleading evidence, which alters the state of evidence presented to the jury. The court indicated that such an error ordinarily leads to a substantial miscarriage of justice unless the conviction was inevitable regardless of the error.
The court concluded that the criteria specified in subsection 353A(1) were satisfied, and it was appropriate to proceed to consider whether a substantial miscarriage of justice had occurred. The court found that the new evidence was fresh and compelling and that it was in the interests of justice to consider it. The court then determined that it was reasonably arguable that there had been a substantial miscarriage of justice, justifying the grant of permission to appeal.
Orders
Orders of the court
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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: GRAY J
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