SUPREME COURT OF SOUTH AUSTRALIA
(Court of Criminal Appeal)
R v M, RS
[2018] SASCFC 37
Judgment of The Court of Criminal Appeal
(The Honourable Justice Peek, The Honourable Justice Nicholson and The Honourable Justice Hinton)
11 May 2018
CRIMINAL LAW - APPEAL AND NEW TRIAL - MISCARRIAGE OF JUSTICE - PARTICULAR CIRCUMSTANCES AMOUNTING TO MISCARRIAGE - IMPROPER ADMISSION OR REJECTION OF EVIDENCE
CRIMINAL LAW - APPEAL AND NEW TRIAL - PARTICULAR GROUNDS OF APPEAL - IMPROPER ADMISSION OR REJECTION OF EVIDENCE - OTHER CASES
CRIMINAL LAW - APPEAL AND NEW TRIAL - PARTICULAR GROUNDS OF APPEAL - MISDIRECTION AND NON-DIRECTION - PRESENTATION OF CROWN CASE
Appeal against conviction.
The appellant was convicted by a judge sitting alone of one count of persistent sexual abuse of a child, contrary to s 50(1) of the Criminal Law Consolidation Act 1935 (SA). The complainant was his step daughter, JLM. The abuse occurred between September 1981 and December 1991 commencing when JLM was around eight years of age. The defence case denied that the sexual acts constituting the abuse alleged occurred. Accordingly the success of the prosecution case depended upon the creditability and reliability of JLM.
In advance of the appellant’s trial counsel for the appellant was advised that the prosecution did not intend to call PMM, JLM’s mother and the appellant’s partner, as a witness for the prosecution. PMM had provided the police with two statements which if accepted, were inconsistent with those provided by JLM and undermined her credibility. In particular PMM denied that JLM had twice complained to her about being sexually abused by the appellant.
Prior to the commencement of the trial the appellant made a formal application that the trial Judge invite the prosecutor to reconsider the decision not to call PMM. The prosecutor explained to the trial Judge that he had met with both JLM and PMM in addition to LID, JLM’s younger sister. The prosecutor said he had no reason to think that JLM was not a witness of truth. He considered that he could not present PMM as a witness of truth explaining that PMM was adamant that her husband had not committed the offence and that JLM had either imagined or made up the allegations. The prosecutor said PMM was available for the defence to call as a witness.
The application was refused and reasons provided for the refusal: R v M, RS [2016] SADC 166. The trial commenced and at the close of the prosecution case the application was renewed. Again the trial Judge refused the application, providing his ruling before the defence case was opened, and his reasons for that ruling some months later, the same day on which the appellant was found guilty: R v M, RS (No 2) [2017] SADC 23.
On appeal the appellant argued that a miscarriage of justice had occurred because of the prosecution’s decision not to call PMM to give evidence. By his second ground of appeal the appellant argued that the reasons of…
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CaseChat Overview and Summary
The central legal issue before the Court of Appeal was whether the trial judge's reasons for dismissing the renewed application demonstrated bias, specifically prejudgment of the case. The appellant contended that the trial judge had formed concluded views on the credibility of the prosecution's key witness, JLM, and other supporting witnesses, before the defence case had been presented or addresses had been made. This, it was argued, suggested that the judge had prejudged the reliability of the evidence and therefore could not bring an impartial mind to the application.
The Court of Appeal considered the principles established in *Apostilides*, which govern when a prosecutor's decision not to call a witness can lead to a miscarriage of justice. These principles state that such a decision will only be a ground for setting aside a conviction if, viewed against the conduct of the trial as a whole, it results in a miscarriage of justice, and that the focus is on the consequences of the failure to call the witness, not necessarily on prosecutorial misconduct. The appellant argued that the trial judge's strong pronouncements on JLM's credibility and reliability, and the dismissal of PMM's potential evidence, indicated a prejudgment that disadvantaged the appellant. The respondent countered that the judge's findings were necessary for the application and were provisional, akin to findings made on a voir dire.
The Court of Appeal granted permission to appeal on the first ground, finding that the appellant's argument regarding the trial judge's potential bias had merit. The court indicated that the trial judge's reasons for refusing the renewed application did exhibit a degree of prejudgment concerning the credibility of witnesses, which could lead to a reasonable apprehension of bias and potentially a miscarriage of justice.
Orders
Orders of the court
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Background
Background to the litigation
Evidence
Evidence Before The Court
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
Established by: PEEK J, NICHOLSON J, HINTON J
In Apostilides the High Court reduced the applicable principles in this area of discourse to the following six propositions:[51][51] (1984) 154 CLR 563 at 575. See also Diehm v DPP (Nauru) (2013) 88 ALJR 34 at [64] (French CJ, Kiefel and Bell JJ).1.The Crown prosecutor alone bears the responsibility of deciding whether a person will be called as a witness for the Crown.2.The trial judge may but is not obliged to question the prosecutor in order to discover the reasons which led the prosecutor to decline to call a particular person. He is not called upon to adjudicate the sufficiency of those reasons.3.Whilst at the close of the Crown case the trial judge may properly invite the prosecutor to reconsider such a decision and to have regard to the implications as then appear to the judge at that stage of the proceedings, he cannot direct the prosecutor to call a particular witness.4.When charging the jury, the trial judge may make such comment as he then thinks to be appropriate with respect to the effect which the failure of the prosecutor to call a particular person as a witness would appear to have had on the course of the trial. No doubt that comment, if any, will be affected by such information as to the prosecutor's reasons for his decision as the prosecutor thinks it proper to divulge.5.Save in the most exceptional circumstances, the trial judge should not himself call a person to give evidence.6.A decision of the prosecutor not to call a particular person as a witness will only constitute a ground for setting aside a conviction if, when viewed against the conduct of the trial taken as a whole, it is seen to give rise to a miscarriage of justice.The Court was also concerned to point out that:[52]In our formulation of the sixth proposition we have omitted the reference to misconduct, intending thereby to broaden the approach so as to focus directly on the consequences, objectively perceived, that the failure to call the witness has had on the course of the trial and its outcome. It is not necessary to postulate misconduct of the prosecutor as an essential condition precedent to a miscarriage of justice. No doubt in the great majority of cases of this kind an appellate tribunal which finds a miscarriage of justice to have occurred will trace that miscarriage to a wrong exercise of judgment by the prosecutor which led to the witness not being called. In cases where there has been no error of judgment there will be less likelihood of a miscarriage resulting from the failure to call the witness. Nevertheless, the absence of testimony from a witness may lead to a miscarriage of justice without any error having occurred. Whitehorn was regarded as such a case, by some at least of the members of the Court who took part in that decision. The absence, for whatever reason, of any evidence from the complainant was the basic reason, in the light of such evidence as was called, for the Court's conclusion that the verdict was unsafe and unsatisfactory. So, if a prosecutor fails to call a witness whose evidence is essential to the unfolding of the case for the Crown the central question is not whether his decision constitutes misconduct but whether in all the circumstances the verdict is unsafe or unsatisfactory.[footnotes omitted][52] The Queen v Apostilides (1984) 154 CLR 563 at 577.c. Consideration