NEW SOUTH WALES COURT OF CRIMINAL APPEAL
CITATION: REGINA v QUACH [2002] NSWCCA 519
FILE NUMBER(S):
60311/02
HEARING DATE(S): 29/11/02
JUDGMENT DATE: 20/12/2002
PARTIES:
Regina
Tan Gai Quach
JUDGMENT OF: Spigelman CJ Sully J James J
LOWER COURT JURISDICTION: District Court
LOWER COURT FILE NUMBER(S): 01/11/0930
LOWER COURT JUDICIAL OFFICER: Andrew DCJ
COUNSEL:
A J Bellanto QC / P Byrne SC (Appellant)
D M L Woodburne (Crown)
SOLICITORS:
Borak & Co (Appellant)
S E O'Connor (Crown)
CATCHWORDS:
CRIMINAL LAW
EVIDENCE
Admissibility of evidence of prior criminal conduct where not adduced for tendency purpose
Relationship between propensity evidence at common law and tendency evidence under Evidence Act 1995
Where accused was subject of telephone intercepts said to reveal prior heroin supplies
Where accused charged with supplying heroin
CRIMINAL LAW
DIRECTIONS TO JURY
Whether directions to jury about evidence of prior criminal conduct were adequate to prevent tendency reasoning
Where directions were given in terms requested by accused's counsel
CRIMINAL LAW
EVIDENCE
Improperly obtained admissions
Discretion to admit ERISP
Where answers obtained after accused claimed right to silence
Where caution not given until part way through interview
Whether cause to believe truth of answers adversely affected
LEGISLATION CITED:
Drug Misuse and Trafficking Act 1985
Evidence Act 1995
DECISION:
Appeal dismissed
JUDGMENT:
- 42 -
IN THE COURT OF
CRIMINAL APPEAL
60311/02
SPIGELMAN CJ
SULLY J
JAMES JFriday 20 December 2002
REGINA v Tan Gia QUACH
Judgment
SPIGELMAN CJ: I have had the benefit of reading the judgment of Sully J in draft. I agree generally with his Honour’s reasons but wish to add some observations on the admissibility of the intercepted telephone calls. The submissions in this respect were expressed in terms of “tendency reasoning”, invoking s97 of the Evidence Act 1995. A parallel submission could perhaps have been based on “coincidence”, invoking s98. Nothing turns on the distinction and I will focus on s97 as the submissions did.
The Appellant’s submissions proceeded on the basis that the intercepts were only admissible as “contextual background” to prove an association between the Appellant and Phuong Tan Le. It was submitted to this Court, but not to the trial judge, that for that purpose parts of the conversations could have been admitted without any reference to drugs. A distinction was suggested between the use of the tapes to establish the fact and frequency of conversations between Le and the Respondent, the relevance of which was conceded, and the content of the conversations.
The trial judge was not invited to undertake any such task of editing. Nor were the individual conversations analysed separately with a view to a separate decision being made on each of them for any purpose including, for example, the separate application to each of s135 or s137 of the Evidence Act 1995. Experienced counsel objected to the entirety of the tapes, including the evidence of voice identification.
The more refined analysis suggested, but not developed, in submissions to this Court was never attempted below. In any event, there are parts…
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- AGLC
- R v Quach [2002] NSWCCA 519
- Case
- [2002] NSWCCA 519
- Decision Date
CaseChat Overview and Summary
The legal issues before the court included whether the evidence of prior criminal conduct was admissible when not adduced for a tendency purpose and how the common law regarding propensity evidence related to tendency evidence under the Evidence Act 1995. Another issue was whether the interview evidence was improperly obtained, particularly as it was obtained after the appellant claimed his right to silence and was not fully cautioned until partway through the interview. The court also needed to decide whether the trial judge's directions to the jury about the evidence of prior criminal conduct were adequate to prevent any tendency reasoning.
The High Court found that the trial judge was entitled to conclude that the evidence was not unfairly obtained and that there was no impropriety which would outweigh its admissibility. The court held that the trial judge’s directions to the jury were sufficient to prevent any tendency reasoning. The court reasoned that despite the delay in giving the caution, the appellant understood that his answers could be used in court and had acknowledged that his responses were given of his own free will. Therefore, the evidence was properly admitted, and the appellant's challenge to the admissibility of the evidence was dismissed.
The High Court upheld the conviction, confirming that the evidence in question was properly admitted and that the trial judge's directions to the jury were adequate. The court found no basis to order a new trial or to quash the conviction.
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
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Ratio Decidendi
Legal Principle Established
Established by: SPIGELMAN CJ SULLY J
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