SUPREME COURT OF SOUTH AUSTRALIA
(Court of Criminal Appeal)
R v LINDSAY
[2014] SASCFC 56
Judgment of The Court of Criminal Appeal
(The Honourable Chief Justice Kourakis, The Honourable Justice Gray and The Honourable Justice Peek)
3 June 2014
CRIMINAL LAW - GENERAL MATTERS - CRIMINAL LIABILITY AND CAPACITY - DEFENCE MATTERS - PROVOCATION - AVAILABILITY OF DEFENCE
CRIMINAL LAW - GENERAL MATTERS - CRIMINAL LIABILITY AND CAPACITY - DEFENCE MATTERS - PROVOCATION - CONDUCT CAPABLE OF AMOUNTING TO
CRIMINAL LAW - GENERAL MATTERS - CRIMINAL LIABILITY AND CAPACITY - DEFENCE MATTERS - PROVOCATION - DIRECTIONS TO JURY
CRIMINAL LAW - GENERAL MATTERS - CRIMINAL LIABILITY AND CAPACITY - DEFENCE MATTERS - PROVOCATION - EVIDENCE
CRIMINAL LAW - GENERAL MATTERS - CRIMINAL LIABILITY AND CAPACITY - DEFENCE MATTERS - PROVOCATION - OBJECTIVE TEST: ORDINARY PERSON
CRIMINAL LAW - GENERAL MATTERS - CRIMINAL LIABILITY AND CAPACITY - DEFENCE MATTERS - PROVOCATION - PROPORTIONALITY OF RESPONSE
CRIMINAL LAW - SENTENCE - RELEVANT FACTORS - NATURE AND CIRCUMSTANCES OF OFFENCE - PROVOCATION
CRIMINAL LAW - PARTICULAR OFFENCES - OFFENCES AGAINST THE PERSON - HOMICIDE - MURDER - SENTENCE: PARTICULAR CASES - MINIMUM TERM, NON-PAROLE PERIOD
CRIMINAL LAW - SENTENCE - SENTENCING ORDERS - NON-PAROLE PERIOD OR MINIMUM TERM - SOUTH AUSTRALIA - DISCRETION TO REFRAIN FROM FIXING
CRIMINAL LAW - SENTENCE - RELEVANT FACTORS - TIME SPENT IN CUSTODY
CRIMINAL LAW - SENTENCE - SENTENCING PROCEDURE - MATERIAL RELEVANT FOR DETERMINING APPROPRIATE SENTENCE
Appeal against conviction for murder. Application for permission to appeal against sentence.
The appellant met the deceased whilst drinking with others and invited him to his home for further drinks. There the deceased made two homosexual advances toward him in the presence of his female partner, their child, and two of his sisters. After the first advance, the deceased was told the appellant was not gay and warned that violence would follow if he continued with such suggestions. The prosecution case was that the appellant attacked and killed the deceased with a knife after he made a further, second advance. The primary line of defence was that it was his co-accused who committed the attack whilst the appellant was elsewhere in the house. The secondary line of defence was that the partial defence of provocation (directly inconsistent with the primary defence) was not negated and that a verdict of manslaughter should be returned. The appellant was convicted of murder, and sentenced to life imprisonment with a 23 year non-parole period. The co-accused was acquitted of murder and manslaughter. The appellant appealed against conviction on the ground that the Judge’s directions on provocation were incorrect or inadequate. The appellant also applied for permission to appeal against sentence.
Held (Peek J, Kourakis CJ agreeing, dismissing the appeal against conviction):
1. The Judge in directing the jury failed to address the distinction within the objective limb between the gravity of provocation (where the appellant’s personal traits must be taken into account) and the matter of loss of self-control (where, excluding age, they must…
Continue reading R v Lindsay
Sign in free to access the full text
- AGLC
- R v Lindsay [2014] SASCFC 56
- Case
- [2014] SASCFC 56
- Decision Date
CaseChat Overview and Summary
The central legal issue before the Full Court of the Supreme Court of South Australia was whether the trial judge's directions on the partial defence of provocation were legally correct and sufficiently comprehensive. Specifically, the appeal raised questions about the judge's failure to adequately identify the evidence supporting provocation, the proper application of the subjective and objective tests for provocation, the definition of "loss of self-control," the link between loss of control and the act causing death, the use of rhetorical questions that may have undermined the defence, and the jury's entitlement to rely on the co-accused's evidence. The appeal also questioned the judge's directions concerning the use of a statement made by Lindsay and the impact of prosecution submissions that allegedly misstated the law.
The Full Court found that while there may have been some deficiencies in the judge's directions regarding the partial defence of provocation, these errors did not lead to a miscarriage of justice. The Court emphasised that the prosecution's case for murder was extremely strong and that the jury's unanimous verdict of murder indicated they had found all elements of the offence proven and had not been swayed by the provocation defence. The Court noted that the defence counsel's strategy had, in part, relied on the judge leaving provocation to the jury, and that any error in this regard was intertwined with the defence's own tactical decisions.
Ultimately, the appeal against conviction was dismissed. The Court also refused permission to appeal against the sentence, finding no error in the sentencing judge's approach, noting the brutal nature of the crime, Lindsay's criminal history, and the assessment that he posed an ongoing danger to the public.
Orders
Orders of the court
Full text does not contain this section.
Background
Background to the litigation
Full text does not contain this section.
Evidence
Evidence Before The Court
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
Established by:
The partial defence of provocation was directly contrary to the primary line of defence and the effect of the defence address was to impliedly suggest that the jury might concentrate on the partial defence of provocation; no doubt, if the Judge had indicated that he would not leave provocation, counsel would have structured his address very differently, solely relying on the primary line of defence in an unqualified fashion. It may therefore be argued that if the Judge’s decision to leave provocation is now said to have been in error (thus opening the way to the application of the proviso), then such error was also responsible for the decision of defence counsel to structure his closing address to the detriment of his primary defence. Considerations militating in favour of the application of the proviso There are a number of considerations strongly militating in favour of the application of the proviso here.The prosecution case on the charge of murder was extremely strong It is to be emphasised that the prosecution case that the appellant caused the death of the deceased by deliberately stabbing him while holding the requisite intent for murder was an extremely strong one. I will not assay an analysis of the evidence; the proposition is indisputable and was not disputed on appeal. It is notable that very experienced senior counsel for the appellant never sought to proffer any ground of appeal suggesting that the conviction of murder was vulnerable to any attack except by the route of complaint as to manslaughter not being properly left to the jury. She was clearly right in taking that approach.The fact that the jury unanimously convicted of murder In my view, the mere existence of a conviction is seldom of great assistance in relation to the application of the proviso since the very question before the court of appeal so often concerns the propriety of that conviction having regard to various errors asserted to be possibly responsible for it. However, here the situation is an unusual one. The jury were plainly instructed that they were required to find all the elements of murder proven before deciding whether the prosecution had negatived the alternative of manslaughter and their verdict demonstrates that they did so. There is no error said to attach to the conviction of the charge of murder apart from the matters pertaining to the alternative of manslaughter. There is therefore a logical way in which it can be said that this verdict does tend to confirm the Court’s own assessment that the case is a strong one. [124][124] For completeness, cases such as Gilbert The Queen (2000) 201 CLR 414 and Gillard v The Queen (2003) 219 CLR 1 stand for the proposition that a choice by the jury to convict of a charge of murder is to be viewed against a background of the alternatives available, including not only the possibility of acquittal but also the possibility of an alternative verdict of manslaughter. While primarily applying to a case where a Judge errs in failing to leave manslaughter at all, the principle may have some application where the alternative verdict is left with inadequate directions. However, in the context of the present circumstances the finding that the Judge’s directions were inadequate diminishes only to a minor degree the weight to be attached to the fact that the jury were prepared to convict of the charge of murder.