SUPREME COURT OF SOUTH AUSTRALIA
(Court of Criminal Appeal)
R v N, SH
[2010] SASCFC 74
Judgment of The Court of Criminal Appeal
(The Honourable Justice Sulan, The Honourable Justice Anderson and The Honourable Justice David)
21 December 2010
CRIMINAL LAW - EVIDENCE - PROPENSITY, TENDENCY AND CO-INCIDENCE - JOINDER OF PERSONS OR COUNTS
CRIMINAL LAW - EVIDENCE - JUDICIAL DISCRETION TO ADMIT OR EXCLUDE EVIDENCE - PREJUDICIAL EVIDENCE - GENERALLY
CRIMINAL LAW - APPEAL AND NEW TRIAL - VERDICT UNREASONABLE OR INSUPPORTABLE HAVING REGARD TO EVIDENCE
Appeal against conviction – appellant convicted at trial of two counts of persistent sexual exploitation against a child against his step-daughter and step-granddaughter – whether separate trials should have been ordered – whether judge should have asked jury for special findings in relation to pleaded particulars – whether photographs tendered at trial were inadmissible – whether the verdict of guilty in relation to count 2 is unreasonable and cannot be supported by the evidence.
Held: appeal allowed and convictions set aside – similarity between count 1 and count 2 is unremarkable and falls well short of required probative force to justify cross admissibility – separate trials should have been ordered – judge erred in admitting photographs and failing to direct jury as to their use – open to the jury to be satisfied of the guilt of the accused on count 2 – appeal allowed and convictions set aside – retrials ordered on each count, to be tried separately.
Criminal Law Consolidation Act 1935 (SA) s 50, s 278, referred to.
R v Spanos (2007) 99 SASR 487; De Jesus v The Queen (1986) 68 ALR 1; Sutton v The Queen (1984) 152 CLR 528; R v Hoch (1988) 165 CLR 292; Phillips v The Queen (2006) 225 CLR 202; R v Ellis [2010] SASC 118; M v The Queen (1994) 181 CLR 487; Weiss v The Queen (2002) 224 CLR 300, applied.
R v N, SH
[2010] SASCFC 74Court of Criminal Appeal: Sulan, Anderson and David JJ
THE COURT.
Introduction
The appellant appeals against his convictions on two counts of persistent sexual exploitation of a child contrary to s 50 of the Criminal Law Consolidation Act 1935 (SA) (“the Act”). The victims of his offending were his step-daughter (“V1”) (Count 1) and his step-granddaughter (“V2”) (Count 2).
Before the empanelling of the jury the appellant sought separate trials in respect of the two counts on the information. The application was refused by the trial Judge. The appellant now argues that the failure to order separate trials was erroneous and has resulted in a miscarriage of justice.
The appellant also argues that certain photographs tendered at the trial, in relation to count 2 and which were objected to, were inadmissible. Also in relation to count 2 he argues that the verdict of guilty is unreasonable and cannot be supported having regard to the evidence.
The charge and the trial
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- R v N, SH [2010] SASCFC 74
- Case
- [2010] SASCFC 74
- Decision Date
CaseChat Overview and Summary
The central legal issues before the Court of Appeal were whether separate trials should have been ordered for the two counts, whether the trial judge erred in failing to seek special findings from the jury regarding the pleaded particulars of the offences, whether certain photographs tendered as evidence were inadmissible, and whether the verdict of guilty on the second count was unreasonable or unsupported by the evidence.
The Court found that the similarity between the two counts was not sufficiently probative to justify their joint admission as evidence for each other, and therefore separate trials should have been ordered. Furthermore, the judge erred in admitting the photographs without adequately directing the jury on their use. While the Court considered the evidence in relation to the second count, it concluded that it was open to the jury to be satisfied of the appellant's guilt on that count.
Ultimately, the appeal was allowed, and the convictions were set aside. The Court ordered retrials on each count, to be conducted separately.
Orders
Orders of the court
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Background
Background to the litigation
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Evidence
Evidence Before The Court
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Decision
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Ratio Decidendi
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