SUPREME COURT OF SOUTH AUSTRALIA
(Criminal)
R v MITCHELL & ORS (No 3)
Criminal Trial by Judge Alone
[2025] SASC 118
Reasons for the Verdict of the Honourable Justice McIntyre
23 July 2025
CRIMINAL LAW - PARTICULAR OFFENCES - OFFENCES AGAINST THE PERSON - HOMICIDE - MURDER
CRIMINAL LAW - PARTICULAR OFFENCES - OFFENCES AGAINST THE PERSON - HOMICIDE - MURDER - CONSTRUCTIVE MURDER
CRIMINAL LAW - GENERAL MATTERS - ANCILLARY LIABILITY - COMPLICITY - COMMON PURPOSE OR JOINT CRIMINAL ENTERPRISE - SCOPE OF AGREEMENT
The defendants are jointly charged with one count of Murder. The offence is alleged to have occurred on 8 or 9 October 2018 while the defendants committed a robbery at a cannabis grow house. The deceased died due to one or more severe blows to the head, delivered by one or more of the defendants with a weapon. The identity of the person who inflicted the blow or blows is not known.
On the prosecution case the four defendants, and JPH who was tried separately, were part of a joint criminal enterprise to commit aggravated robbery. The prosecution contend that each defendant is liable by way of extended joint criminal enterprise; that is, each defendant participated in the agreement to commit robbery despite foreseeing the possibility that a co-offender might, in the course of committing that offence, intentionally occasion death or grievous bodily harm. In the alternative the prosecution case is that, as part of the agreement to commit the robbery, each of the defendants agreed to the possible commission of an intentional act of violence of the same general nature as that inflicted upon the deceased.
Verdict:
1. Each of the defendants are guilty of Murder.
Criminal Law Consolidation Act 1935 (SA) ss 11, 12A.; Criminal Law Consolidation (Felonies and Misdemeanours) Amendment Act (SA); Telecommunications (Interception and Access) Act 1979 (Cth) s 46; Surveillance Devices Act 2016 (SA); Summary Offences Act 1953 (SA), referred to.
Mitchell & Ors v The King (2023) 276 CLR 299, applied.
R v Mitchell & Ors [2024] SASC 52; R v Willoughby (No 2) [2017] SASC 191; Miller v The Queen (2016) 259 CLR 380; Wilson v The Queen (1992) 174 CLR 313; Burns v The Queen (2012) 246 CLR 334; R v Suppiah [2018] SASCFC 11; R v Fragomeli [2008] SASC 96; The Queen v Hendrie (1985) 37 SASR 581; R v Mitchell & Ors (Supreme Court of South Australia, McIntyre J, 2 December 2024) ; Smith v The Queen (2001) 206 CLR 650; Honeysett v The Queen (2014) 253 CLR 122.; R v Mitchell & Ors (No 2) [2024] SASC 68; Shepherd v The Queen (1990) 170 CLR 573; Fitzgerald v The Queen (2014) 311 ALR 158, considered.
R v MITCHELL & ORS (No 3)
[2025] SASC 118Criminal: Trial by Judge Alone
McIntyre J:
Executive summary
Brief outline of the prosecution case
Procedural background
Relevant law
Murder
Robbery
Extended joint criminal enterprise
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- AGLC
- R v Mitchell (No 3) [2025] SASC 118
- Case
- [2025] SASC 118
- Decision Date
CaseChat Overview and Summary
The court examined the evidence presented, including witness testimonies, circumstantial evidence, and the context of the crime. The court found that there was a plan among the defendants and JPH to steal Mr Gjabri’s cannabis, with sufficient evidence to establish their involvement. The court also considered the defendants' intentions regarding the use of force or threat during the robbery. The circumstantial evidence, such as phone records, text messages, and physical evidence, supported the conclusion that at least one of the defendants intended to use force.
In its reasoning, the court applied principles of circumstantial evidence and the onus of proof beyond reasonable doubt. The court emphasised the need for guilt to be the only rational inference from the established facts, excluding any reasonable explanation consistent with innocence. The court found that the defendants’ actions and the surrounding circumstances were consistent with their participation in a joint criminal enterprise and the use of force during the robbery, leading to Mr Gjabri’s death. The court concluded that the defendants were guilty of murder under the doctrine of extended joint criminal enterprise.
Orders
Orders of the court
Full text does not contain this section.
Background
Background to the litigation
Evidence
Evidence Before The Court
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
It is not necessary for a court, having conducted a trial by judge alone, to set out in the reasons for verdict the standard or obvious directions of which the trial judge is bound to be aware. I do nevertheless set out some of the principles that I have applied in this matter. Onus of proof and separate consideration The onus of proof is beyond reasonable doubt. Each defendant is presumed innocent unless, and until, his guilt has been proved beyond reasonable doubt. This requirement extends to proof beyond reasonable doubt of every element of the offence charged. To the extent that any defendant has put forward a defence, or innocent explanation, he does not have to prove it. The burden of proving an offence lies wholly upon the prosecution. It is not sufficient for the prosecution to show a suspicion of guilt or that a defendant is probably guilty. A defendant can only be found guilty of an offence if the evidence proves his guilt beyond a reasonable doubt. Each defendant, and the evidence admissible in relation to him, must be given separate consideration. The right to silence No defendant gave evidence. The exercise of that right must not be used against a defendant. It must not be treated as an admission, nor can it be used to fill in gaps in the prosecution evidence. This does not make the prosecution case stronger or more persuasive. Mitchell gave evidence at the previous trial. The transcript was read in this trial and formed part of the prosecution case. Mitchell’s evidence was given on oath. I did not have the opportunity to see and hear Mitchell give the evidence, nor have I had the opportunity to assess his demeanour when tested in cross examination. I will assess his evidence from the previous trial in the same way as I assess the evidence of other witnesses. I will not treat this evidence as deserving less weight simply because Mitchell is a defendant. I can give it whatever weight I consider it deserves. Circumstantial evidence The prosecution relies upon circumstantial evidence. A guilty verdict cannot be returned unless the evidence is inconsistent with any reasonable hypothesis other than guilt. Guilt must be the only rational inference. There are two steps in approaching a circumstantial case. First, it is necessary to consider the evidence upon which the prosecution relies and decide what facts are established. Second, is the need to consider what inference, or inferences, can be drawn from the established facts. The second step requires a consideration of the combined strength of the facts established by the evidence. There cannot be a guilty verdict unless the circumstances exclude any reasonable explanation consistent with innocence. In other words, before any defendant can be found guilty of an offence, guilt must be the only rational inference to be drawn from the facts or circumstances which I accept are established on the evidence. Witnesses In making findings of fact, I must rely upon the evidence given by the witnesses and the evidence contained in the exhibits. I must apply my common sense; I have reminded myself of the usual directions given in this state to juries concerning the proper approach to assess the various witnesses who gave evidence, their credibility and reliability.