SUPREME COURT OF SOUTH AUSTRALIA
(Court of Criminal Appeal)
R v NGUYEN
[2009] SASC 91
Judgment of The Court of Criminal Appeal
(The Honourable Chief Justice Doyle, The Honourable Justice Sulan and The Honourable Justice David)
8 April 2009
CRIMINAL LAW - JURISDICTION, PRACTICE AND PROCEDURE - WITNESSES - POWER OF CROWN TO CALL OR REFUSE TO CALL WITNESSES - DISCRETION OF CROWN - GENERALLY
EVIDENCE - BURDEN OF PROOF, PRESUMPTIONS, AND WEIGHT AND SUFFICIENCY OF EVIDENCE - GENERALLY - CREDIBILITY AND WEIGHT - PARTY'S FAILURE TO GIVE OR CALL EVIDENCE
Appellant appealed against conviction on charge of aggravated causing serious harm with intent to cause serious harm - prosecution decided not to call witness listed on Information because it determined witness dishonest and unreliable - decision not in breach of prosecutor’s duty to call all material witnesses - whether trial judge erred in not directing jury they were entitled to infer evidence of that absent witness would not have assisted prosecution case - whether trial judge erred in not directing jury that if quality of prosecution evidence was diminished by the absence of that witness, then that was relevant to whether prosecution had proved charge beyond reasonable doubt.
Held (dismissing the appeal): Because decision not to call witness listed on Information was not in breach of prosecutor's duty to call material witnesses, trial judge did not err in not directing jury they were entitled to infer evidence of that absent witness would not have assisted prosecution case - trial judge gave sufficient directions on evidence and onus of proof that applied to that evidence - trial judge did not err in not providing further directions.
CRIMINAL LAW - APPEAL AND NEW TRIAL AND INQUIRY AFTER CONVICTION - APPEAL AND NEW TRIAL - PARTICULAR GROUNDS - IMPROPER ADMISSION OR REJECTION OF EVIDENCE - GENERAL PRINCIPLES
EVIDENCE - DOCUMENTARY EVIDENCE - STATUTORY PROVISIONS AS TO STATEMENTS IN DOCUMENTS WHERE DIRECT ORAL EVIDENCE ADMISSIBLE - WHERE MAKER OF STATEMENT NOT ATTENDING AS WITNESS
At trial defence challenged identification of appellant as gunman - defence case was that victim had motive to lie and others had motive to harm him - passage of statement of witness, who could not be called, sought to be admitted by defence into evidence - whether trial judge erred in rejecting admission of passage of statement into evidence.
Held (dismissing the appeal): Even if witness could be called to give evidence, what he said in passage of statement would not be admissible - as passage of statement would not be admissible, it would have been contrary to interests of justice to admit it.
Criminal Law Consolidation Act 1935 (SA) s 11, s 23(1), s 270A; Evidence Act 1929 (SA) s 45A, s 45B, referred to.
Police v Kyriacou [2009] SASC 66; R v Apostilides (1984) 154 CLR 563, applied.
Dyers v The Queen (2002) 210 CLR 285, discussed.
Jones v Dunkel (1959) 101 CLR 298; Louizos v The Queen [2009] NSWCCA 71; Mahmood…
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- AGLC
- R v Nguyen [2009] SASC 91
- Case
- [2009] SASC 91
- Decision Date
CaseChat Overview and Summary
The legal issues before the court were whether the trial judge erred in not directing the jury that they were entitled to infer that the evidence of the absent witness would not have assisted the prosecution case and that the absence of that witness was relevant to whether the prosecution had proved the charge beyond reasonable doubt. The court found that because the decision not to call the witness was not in breach of the prosecutor's duty to call material witnesses, the trial judge did not err in not directing the jury that they were entitled to infer that the evidence of the absent witness would not have assisted the prosecution case. The court found that the trial judge gave sufficient directions on the evidence and onus of proof that applied to that evidence and that the trial judge did not err in not providing further directions.
The court dismissed the appeal and upheld the conviction. The court found that the trial judge had given adequate directions to the jury on the evidence and onus of proof that applied to that evidence, and that the absence of the witness Hong did not affect the quality of the prosecution evidence or the jury's assessment of it. The court found that the prosecution had proved the charge of aggravated causing serious harm with intent to cause serious harm beyond reasonable doubt and that the trial judge had not erred in his directions to the jury. The conviction was upheld, and no further orders were made.
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
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