SUPREME COURT OF SOUTH AUSTRALIA
(Court of Criminal Appeal)
SAN v THE QUEEN
[2020] SASCFC 35
Judgment of The Court of Criminal Appeal
(The Honourable Chief Justice Kourakis, The Honourable Justice Stanley and The Honourable Justice Lovell)
8 May 2020
CRIMINAL LAW - PARTICULAR OFFENCES - OFFENCES AGAINST THE PERSON - SEXUAL OFFENCES
CRIMINAL LAW - APPEAL AND NEW TRIAL - PARTICULAR GROUNDS OF APPEAL - MISDIRECTION AND NON-DIRECTION - PARTICULAR CASES - WHERE APPEAL ALLOWED
CRIMINAL LAW - APPEAL AND NEW TRIAL - VERDICT UNREASONABLE OR INSUPPORTABLE HAVING REGARD TO EVIDENCE - APPEAL DISMISSED
CRIMINAL LAW - PROCEDURE - INFORMATION, INDICTMENT OR PRESENTATION - AVERMENTS - UNCERTAINTY, DUPLICITY AND AMBIGUITY
Appeal against conviction and sentence for one count of indecent assault contrary to s 56 of the Criminal Law Consolidation Act 1935 (SA) (the CLCA) (count 1) and making a communication, on Facebook Messenger, with the intention of making a child, SM, amenable to a sexual activity contrary to s 63B(3) of the CLCA (count 2 or the sexual communication offence).
SM met the appellant at a pool lounge, which she frequented with her family, when she was 13 years old. The appellant sent her a friend request on Facebook and started communicating with SM once she accepted the request at his prompting. The sexual communication offence concerned social media communications on 12 September 2016 engaged in by the appellant with SM. She was aged 16 years at the time of that offence.
The conduct the subject of count 1 occurred when she was 14 years old on an occasion when she returned home from school to find the appellant playing pool with her stepfather. She watched them play pool, during which the appellant touched her when her stepfather left the room.
The appellant appeals on the grounds that:
1. The Judge erred in failing to direct the jury that it could not convict if the appellant might have intended to make SM amenable to a sexual activity to occur when she was not a child.
2. Count 2 on the Information is duplicate.
3. The Judge erred in failing to direct in accordance with s 34CB(2) of the Evidence Act 1929 (SA).
4. The verdict in count 1 is unreasonable.
5. The verdict in count 2 is unreasonable.
Held per Kourakis CJ (Stanley and Lovell JJ agreeing), allowing the appeal on ground 1, and granting permission to appeal on grounds 3, 4 and 5, but dismissing the appeal on grounds 2, 3, 4 and 5:
1. It is an element of the sexual communication offence that the offender intended to make the child, who is the subject of the communication, amenable to engaging in sexual activity whilst still a child.
2. It is necessary to set aside the single sentence of three years’ imprisonment imposed with respect to both offences and to order a new trial on the sexual communication offence.
3. It is not necessary to consider the application for permission to appeal against sentence.
4. An…
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- San v The Queen [2020] SASCFC 35
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- [2020] SASCFC 35
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CaseChat Overview and Summary
The central legal issues before the court were whether the jury's verdict on the indecent assault charge was unreasonable or unsupported by the evidence, and whether there had been a misdirection or non-direction by the trial judge concerning the sexual communication offence. The appellant also contended that the only reasonable inference from the evidence regarding Facebook communications was that SM had altered them, which would undermine the prosecution's case.
The Full Court, in a joint judgment, considered the evidence presented, including SM's testimony about the indecent assault and the Facebook communications. The court found that even if the jury were satisfied that some messages were deleted, this could reasonably be attributed to embarrassment rather than an attempt to fabricate evidence. The court concluded that the remaining messages were capable of proving the sexual communication offence and circumstantially supporting SM's evidence regarding the indecent assault.
Consequently, the Full Court allowed the appeal against the conviction for the sexual communication offence, finding it necessary to set aside the sentence and order a new trial on that charge. However, the appeal against the conviction for indecent assault was dismissed. The application for permission to appeal against sentence was rendered unnecessary due to the order for a new trial.
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Background
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