Secretary to the Department of Justice and Regulation v Bhatia

Case

[2018] VSC 500

4 September 2018

IN THE SUPREME COURT OF VICTORIA Not Restricted
AT MELBOURNE
COMMON LAW DIVISION
JUDICIAL REVIEW AND APPEALS LIST

S CI 2018 00532

SECRETARY TO THE DEPARTMENT OF JUSTICE Applicant
AND REGULATION
v
KULVINDER BHATIA Respondent

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JUDGE: Richards J
WHERE HELD: Melbourne
DATE OF HEARING: 30 July 2018
DATE OF JUDGMENT: 4 September 2018
CASE MAY BE CITED AS: Secretary to the Department of Justice and Regulation v
Bhatia
MEDIUM NEUTRAL CITATION: [2018] VSC 500

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ADMINISTRATIVE LAW – Appeal – Victorian Civil and Administrative Tribunal – Secretary revoked respondent’s assessment notice under Working with Children Act 2005

Respondent pleaded guilty to offensive behaviour in a public place under Summary Offences

Act 1966 s 17(1)(d), arising from his presence in female public toilet – Decision of Tribunal to direct Secretary to give assessment notice to respondent – Tribunal found that respondent entered female toilet by mistake, with no ill intent – Whether Tribunal impugned finding of guilt – Whether Tribunal’s findings inconsistent with essential factual elements of offence – Elements of offence of offensive behaviour in a public place – Tribunal’s findings not inconsistent with essential factual elements of offence – Appeal

dismissed – Victorian Civil and Administrative Tribunal Act 1998 (Vic), s 148 – Working with

Children Act 2005 (Vic), ss 14(3) and 26C – Summary Offences Act 1966 (Vic), s 17(1)(d).

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APPEARANCES: Counsel Solicitors
For the Applicant  Mr C Horan QC with Working with Children
Mr A Sim Check Unit, Department of
Justice and Regulation
For the Respondent  Ms K Bowshell KCL Law
HER HONOUR: 

1           On 30 March 2017 the Secretary to the Department of Justice and Regulation revoked

an assessment notice held by Kulvinder Bhatia under the Working with Children Act

2005 (Vic) (WWC Act). The Secretary revoked Mr Bhatia’s notice because he had

been charged with two offences under the Summary Offences Act 1966 (Vic)

(Summary Offences Act) – unlawful assault and behaving in an indecent manner in

a public place. Both charges arose from Mr Bhatia’s presence in a female public

toilet in Bendigo on the night of 22 November 2016.

2           Mr Bhatia applied to the Victorian Civil and Administrative Tribunal for review of

the Secretary’s decision. His application was heard on 6 November 2017 by Deputy

President Lambrick of the Tribunal. At the end of the hearing the Deputy President

allowed the application and directed the Secretary to give an assessment notice to

Mr Bhatia.

3 The Secretary seeks leave to appeal from that order to this Court, under s 148 of the

Victorian Civil and Administrative Tribunal Act 1998 (Vic) (VCAT Act). An appeal

under s 148 may only be brought on a question of law. The Secretary also seeks an

extension of time, under s 148(5) of the VCAT Act. In this case, the applications for

an extension of time and for leave to appeal and the proposed appeal were all

argued together.

4           For the reasons that follow I have decided to extend time to apply for leave to

appeal, to grant leave to appeal in relation to the first question of law identified by

the Secretary, but to dismiss the appeal.

Working with Children Act 2005

5           The WWC Act was enacted for the main purpose of assisting in protecting children

from sexual or physical harm by ensuring that people who work with, or care for,

them are subject to a screening process.[1] It is a criminal offence to engage in child-
related work[2] without a current assessment notice under the WWC Act.[3]

[1] WWC Act, s 1(1).

[2]              The expression ‘child-related work’ is defined in s 9 of the WWC Act.

[3] WWC Act, s 33(1).

6 Section 1A emphasises the protective purpose of the legislation:

Protection of children to be paramount

When the Secretary or VCAT makes a decision or takes an action under this Act, the protection of children from sexual and physical harm must be the paramount consideration.

7           A person may apply to the Secretary for a working with children check to be carried

out and an assessment notice to be given to him or her on completion of that check.[4]

[4]              WWC Act, s 10(1).

If granted, an assessment notice must state that the person in respect of whom it was

issued has passed a working with children check.[5] An assessment notice remains in

[5]              WWC Act, s 17(2)(a).

force for 5 years, unless it is revoked or surrendered earlier.[6]

[6]              WWC Act, s 19(1).

8 Part 2, Division 5 of the WWC Act deals with Re-assessment. Section 21(1) of the

WWC Act requires the Secretary to re-assess a person’s eligibility to have an

assessment notice in certain circumstances. These include being notified by the

Chief Commissioner of Police under s 41 of a charge.[7] Section 41(1) obliges the Chief

[7] WWC Act, s 21(1)(c).

Commissioner of Police to notify the Secretary as soon as practicable that a person to

whom an assessment notice has been given has been charged with a category A

offence[8] or a category B offence[9] or any other offence of a type that the Secretary has

[8]              WWC Act, s 3(1) defines ‘category A offence’ to mean an offence specified in Schedule 1.

[9]              WWC Act, s 3(1) defines ‘category B offence’ to mean an offence specified in Schedule 2.

requested be notified. The Secretary must also conduct a re-assessment if notified by

any State law enforcement agency of a charge.[10]

[10] WWC Act, s 21(1)(d).

9           A re-assessment by the Secretary falls into one of three categories: A, B or C. In this

case, Mr Bhatia had been charged with an offence other than a category A offence or

category B offence and so the re-assessment of Mr Bhatia’s eligibility was a category

C re-assessment.[11]

[11] WWC Act, s 21AD(1)(c).

10 A category C re-assessment is governed by s 21AD of the WWC Act, as follows:

(2) The Secretary must determine not to revoke the assessment notice on
a category C re-assessment unless—
(a) the Secretary is satisfied that the person having the assessment notice would pose an unjustifiable risk to the safety of children having regard to the factors set out in subsection (3); or
(b) the Secretary is satisfied that—

(i)          a reasonable person would not allow his or her child to have direct contact with the holder of the assessment notice while the holder was engaged in any type of child-related work; or

(ii)         the holder's engagement in any type of child-related work would pose an unjustifiable risk to the safety of children.

(3) For the purposes of subsection (2)(a), the Secretary must have regard
to—

(a)

the nature and gravity of the conduct and its relevance to child-related work; and

(b)

the period of time since the holder of the assessment notice engaged, or allegedly engaged, in the conduct; and

(c)

in the case of an offence, whether a finding of guilt or a conviction was recorded for it or a charge for it is still pending; and

(d) in the case of an offence, the sentence imposed for it; and

(e)

the ages of the holder and of any victim at the time the holder engaged, or allegedly engaged, in the conduct; and

(f)

whether or not the conduct has been decriminalised or has ceased to be subject to disciplinary charges since the holder engaged, or allegedly engaged, in it; and

(g)

the holder's behaviour since he or she engaged, or allegedly engaged, in the conduct; and

(h)

the likelihood of future threat to a child caused by the holder; and

(i)

any information given by the holder in, or in relation to, the re- assessment; and

(j)

any other matter that the Secretary considers relevant to the re- assessment.

11         Under s 21C(1), the Secretary may revoke an assessment notice following a re-

assessment of the holder’s eligibility to have the notice. If the Secretary proposes to

do so, before making a final decision the Secretary must inform the holder of the

proposal to revoke the assessment notice, invite a submission about the holder’s

eligibility, and give an interim negative notice to the holder.[12] If the Secretary

[12]             WWC Act, s 21AE(1).

decides to revoke an assessment notice, the Secretary must give a negative notice to

the former holder of the assessment notice,[13] together with a written notice stating

[13]             WWC Act, s 21C(2).

the Secretary’s reasons for deciding to revoke the notice and informing the person of

the right to have the decision reviewed by the Tribunal.[14]

[14]             WWC Act, s 21C(3).

12         A person who has been given a negative notice because of a decision of the Secretary

under s 21C(1) to revoke an assessment notice following a category C reassessment

may apply to the Tribunal for review of the decision.[15] In a review of a decision in

[15]             WWC Act, s 26(1)(d).

relation to a category C re-assessment, the Tribunal must determine whether in the

particular circumstances it would be appropriate to refuse to give an assessment

notice, having regard to any matters to which the Secretary must have regard under

s 14(3).[16] Those matters are:

[16] WWC Act, s 26C(1).

(a)

the nature and gravity of the conduct and its relevance to child-related work;

(b)

the period of time since the applicant engaged, or allegedly engaged, in the conduct;

(c)

in the case of an offence, whether a finding of guilt or a conviction was recorded for it or a charge for it is still pending;

(d) in the case of an offence, the sentence imposed for it;

(e)

the ages of the applicant and of any victim at the time the applicant engaged, or allegedly engaged, in the conduct;

(f)

whether or not the conduct has been decriminalised or has ceased to be subject to disciplinary charges since the applicant engaged, or allegedly engaged, in it;

(g)

the applicant's behaviour since he or she engaged, or allegedly engaged, in the conduct;

(h) the likelihood of future threat to a child caused by the applicant;

(i)          any information given by the applicant in, or in relation to, the application; and

(j) any other matter that the Secretary considers relevant to the application.

13 Section 26C(2) provides that the Tribunal must determine that it is appropriate to

refuse to give an assessment notice unless it is satisfied that:

(a) a reasonable person would allow his or her child to have direct contact with the applicant while the applicant was engaged in any type of child-related work; and
(b) the applicant's engagement in any type of child-related work would not pose an unjustifiable risk to the safety of children.

14 Section 26C(3) further provides that, whatever the Tribunal has determined under

ss 26C(1) and (2), it must determine that it is appropriate to refuse to give the

assessment notice unless it is satisfied that it is in the public interest to do so.

Factual background

15         Mr Bhatia held an assessment notice under the WWC Act from 21 January 2011.

Before giving him the assessment notice, the Secretary obtained a police record and

criminal history check that disclosed that Mr Bhatia had no criminal history.[17] In

[17]             Affidavit of Guy Anthony Ventrice sworn 15 February 2018 (Ventrice affidavit), [5]-[6].

January 2016 the Secretary granted Mr Bhatia’s application to renew his assessment

notice.[18]

[18]             Ventrice affidavit, [7].

16         On 12 January 2017 Mr Bhatia was charged with two offences under the Summary

Offences Act: one charge of unlawful assault, under s 23, and one charge of

behaving in an indecent manner in a public place, under s 17(1)(d).[19] The police brief
that accompanied the charges set out the facts alleged by the informant:[20]

[19]             Ventrice affidavit, exhibit GAV-1, pp 76-7.

[20]             Ventrice affidavit, exhibit GAV-1, p 72.

On Tuesday, 22 November 2016, the accused was spending a night in
Bendigo due to work commitments.

During the evening, the accused attended a hotel in Bendigo where he consumed approximately five heavy beers before leaving the hotel.

At approximately 10:15 PM the accused walked to a toilet block which had male and female toilets clearly signed with the relevant gender. At this time, the victim in this matter, was using the toilet inside a cubicle inside the female toilet block.

The accused has then walked to the front entrance of the female toilet and was heard by the female to rattle a locked open gate positioned at the entrance of the female toilet. The woman then heard the accused walk into the toilet block and believes that the accused may have been attempting to close the locked open gate as he was making his way into the toilet.

The woman then observed the accused standing outside her cubicle staring at her through a gap in the cubicle doorway. She asked the accused what he was

doing and informed him that he needed to leave and he can’t be in there. The
accused replied “yes I can. What are you doing?”

The accused continued to stand in the cubicle doorway while the woman stood up from using the toilet. The woman then pushed at the cubicle door to make a noise in an effort to scare the accused into leaving the toilet block. The accused again remained standing in the doorway causing the woman to yell at the accused telling him there was a male and the female toilet. The accused

replied saying “do you want to do something?”

The victim was fearful of the accused and began continually yelling “get out”.

The accused then began to walk backwards toward the toilet block exit while the woman was telling him to leave. As he was walking back away he asked

her “don’t you want any sexual thing?” She told the accused “no” and the

accused has then walked out of the toilet block and sat at a bus stop across the road. The woman then left the scene in her vehicle where she picked up one of her friends before returning. She observed the accused still sitting at the same bus stop. She called police who then spoke to the accused.

  1. The police brief also set out the following ‘Statement made by accused’:[21]

    [21]             Ibid.

    During the interview with the accused, he stated that he had about 4 to 5 beers at the hotel and stayed there for about two hours and was partially drunk. After he left the hotel he was looking for something to eat and he went

    past the toilets and unfortunately went into the ladies’ toilet.

    The accused further stated that he realised he was in the wrong toilet when someone told him and he apologised and walked out. The accused continued to explain that he was in the toilet not even one minute and when he left it was raining so he sat under the shade for the rain to stop.

    The accused denied looking into the cubicle and he denied asking about anything sexual.

    When further questioned about not leaving the toilet when told by [complainant] and entering a female toilet which was clearly signed the accused mentioned that he is a diabetic and he goes to the toilet when he sees them.

    The accused also conceded that he did not end up using a toilet after he walked out of the female toilet.

18         On 19 January 2017 Victoria Police notified the Working With Children Unit of the

Department of Justice and Regulation (WWC Unit) of the charges against Mr

Bhatia.[22] This prompted the Secretary to re-assess Mr Bhatia’s eligibility to have an

[22]             Ventrice affidavit, [8].

assessment notice. The nature of the offences with which he was charged required

the Secretary to conduct a category C reassessment, under s 21AD of the WWC Act.[23]

[23]             Ventrice affidavit, [9].

19         On 14 February 2017 a delegate of the Secretary gave Mr Bhatia an interim negative

notice, under s 21AE, and invited him to make submissions about his eligibility to

have an assessment notice. He did so during March 2017. On 31 March 2017, the

Secretary gave Mr Bhatia a negative notice and revoked his assessment notice, and

provided a statement of reasons for the decision.[24]

[24] Ventrice affidavit, [10]-[12].

  1. Mr Bhatia applied to the Tribunal for review of the Secretary’s decision on 5 May

    2017.[25] At that time the charges were still pending. Mr Bhatia filed an affidavit with

    [25]             Mr Bhatia’s application was made after expiry of the 28-day time limit in s 26(4)(a) of the WWC Act.

    the Tribunal, affirmed on 16 May 2017, in which he said that he was contesting the

    charges. The affidavit set out his account of what happened on the night of 22

    November 2016, which was consistent with his statement recorded in the police

    brief.[26]

    [26] Ventrice affidavit, [16] and exhibit GAV-1, pp 87-117.

  2. Before Mr Bhatia’s application was heard by the Tribunal, the charges against him

    were dealt with in the Magistrates’ Court at Bendigo. On 18 July 2017, police

    withdrew the charge of unlawful assault, and amended the charge of behaving in an

    indecent manner in a public place to a charge of behaving in an offensive manner in

    a public place. On the same day Mr Bhatia pleaded guilty to the charge of behaving

    in an offensive manner in a public place, contrary to s 17(1)(d) of the Summary

    Offences Act.[27]

    [27] Ventrice affidavit, [14]-[15] and exhibit GAV-1, pp 69-70.

22         The Magistrate did not record a conviction. The matter was adjourned for two years

on Mr Bhatia’s undertaking to be of good behaviour during the period of the

adjournment. In addition Mr Bhatia was ordered to pay $1,000 to the Court Fund.[28]

[28] Ibid.

  1. The evidence before the Tribunal of what took place at the Magistrates’ Court in

    Bendigo on 18 July 2017 was incomplete. The Tribunal had the police brief, a

    certified extract recording the disposition of the charge to which Mr Bhatia pleaded

    guilty and a certified extract recording the withdrawal of the unlawful assault

    charge. Neither the recording nor a transcript of the hearing was in evidence, and

    there was no evidence about the Magistrate’s sentencing remarks or his Honour’s

    reasons for not recording a conviction.

24         Mr Bhatia filed a further affidavit, made on 28 September 2017, that included the

following:[29]

[29] Ventrice affidavit, [17] and exhibit GAV-1, pp 125-129.

The Charges were heard in the Magistrates’ Court on 18 July 2017. The

charge of unlawful assault was withdrawn and the charge of behaving in an indecent manner in a public place was reduced to behaving in an offensive manner in a public place. I wanted to dispute, and continue to deny, the

complainant’s allegations that I made sexual comments to her and that I

attempted to shut the entry to the toilet block. But on the advice of my barrister I pleaded to the charge of behaving in an offensive manner in a public place and was released without conviction subject to a good behaviour bond. I believe I probably frightened the complainant when I went into the

ladies’ toilet and made her upset, but I didn’t mean to. I didn’t know that I

was in the ladies’ toilet.

25         Mr Bhatia was cross-examined about what happened at the hearing. He agreed that

the summary of facts in the police brief had been read out to the Magistrate, without

amendment, and that his barrister had not taken issue with the summary.[30]

[30]             Ventrice affidavit, exhibit GAV-1, pp 212-5, 223.

  1. Deputy President Lambrick of the Tribunal heard Mr Bhatia’s application on 6

    November 2017. Mr Bhatia was represented by his solicitor and the Secretary was

    represented by counsel. Mr Bhatia gave evidence, adopting both of his affidavits,

    and was cross-examined. A character witness also gave evidence and was cross-

    examined. No witnesses were called by the Secretary. The Tribunal had written

    submissions filed on behalf of Mr Bhatia and the Secretary and heard oral

    submissions at the conclusion of the hearing that addressed the matters in s 14(3)

    and the tests in s 26C(2) and s 26C(3) of the WWC Act.

27         The Deputy President gave oral reasons for her decision at the conclusion of the

hearing on 6 November 2017, and made the following orders:

1.           The applicant’s application for a review of the decision of the

respondent on 30 March 2017 to revoke the applicant’s Assessment

Notice and issue a Negative Notice to the applicant is allowed.

2.           The respondent is directed to give an Assessment Notice to the applicant under the Working with Children Act 2005.

28         At the request of the parties, the Tribunal provided written reasons for decision on 5

January 2018.[31]

[31]             Bhatia v Secretary to the Department of Justice and Regulation (Review and Regulation) [2017] VCAT 2031 (Reasons).

The Tribunal’s reasons for decision

29         After briefly outlining the factual and procedural background and the material

before the Tribunal, the Deputy President recorded her satisfaction that it was not

appropriate to refuse to give an assessment notice to Mr Bhatia, having regard to

s 14(3) of the WWC Act, or under s 26C(2) and (3) of the WWC Act. She then turned

to consider each of the factors in s 14(3) in turn.

30         In relation to the nature and gravity of the conduct and its relevance to child related

work,[32] the Tribunal noted that the police statement of alleged facts, prepared in

[32] WWC Act s 14(3)(a).

relation to the originally charged offences, was unaltered. She referred to Mr

Bhatia’s evidence about why he pleaded guilty to the amended charge, and then

identified the conundrum she faced in determining the application:[33]

[33] Reasons, [18]-[19].

This created something of a dilemma. If I accepted in full, the following Statement of Alleged Facts, it was difficult to understand why the

withdrawal/substitution of charges occurred. If I accepted Mr Bhatia’s

version, it was difficult to see how any offence had occurred.

The parties invited me to reach my own conclusions on the facts.

31         After setting out the statement of alleged facts and the statement made by the

accused in the police brief,[34] and Mr Bhatia’s denials in his affidavit of 16 May 2017,

[34]             Set out at [16] and [17] above.

the Tribunal continued:[35]

[35] Reasons, [22]-[26].

Mr Bhatia said that he intended defending the charges, but because he wanted to get the matter out of the way and was told by his lawyers that it was a good thing to do, he pleaded guilty and received a non-conviction disposition, expecting and hoping that that would be the end of the matter and he could return to his usual duties at work.

I agreed with the parties’ submission that this case would turn on my

findings about the offending.

If I accepted the police summary in full, Mr Bhatia would have had a difficult task ahead of him in persuading me that he should be granted an Assessment

Notice. Conversely, if I accepted Mr Bhatia’s version that his appearance in

the women’s facilities was accidental and without sinister motive, there

would be no reason to refuse his application.

It is unfortunately the case that this Tribunal is frequently asked to look

behind pleas which often take place “at the door of the Court”. Such pleas

frequently have consequences on a person’s employment which they did not

readily foresee. In Mr Bhatia’s case there has been a significant impact on his

employment. He is unable to continue in his usual role without an
Assessment Notice.

In this case, having heard extensive evidence from Mr Bhatia, I accepted his version of the facts.

32         The Deputy President accepted Mr Bhatia as a credible witness, and made the

following findings about what happened on the night of 22 November 2016:[36]

[36] Reasons, [28]-[37].

(a) Mr Bhatia had drunk a lot more alcohol than usual and was ‘under the

influence’.

(b) He walked into the female toilet block by mistake. He was looking around for

a urinal.

(c) While he was there he exchanged words with the female in the cubicle. She

asked ‘What are you doing here?’ Both of them were taken by surprise at him

being in the female toilet.

(d) This was a ‘horrible mistake’ while Mr Bhatia was under the influence, at

night time and in an unfamiliar situation.

(e) Mr Bhatia’s behaviour was not predatory and he was not looking for a

woman to assault.

(f) He left without incident after the complainant told him to get out.
(g) It would have been a horrible experience for the complainant, as Mr Bhatia

acknowledged.

(h) Mr Bhatia had consistently denied saying any sexual words. While it was

quite possible that the complainant was mistaken, she thought he said the

words she attributed to him.

(i)         After leaving the toilet block Mr Bhatia did not flee but ‘stayed at the scene’,

at a nearby bus shelter.

33         The Deputy President made clear that, had she found that Mr Bhatia was

deliberately in the female toilet, trying to look at a female occupant and making suggested lewd comments, she would not have granted the assessment notice.[37] Her

[37] Reasons, [40].

acceptance of Mr Bhatia’s version of events, in relation to the nature and gravity of

the offending, flowed into all of the other considerations under s 14(3).

34         In relation to the period of time since the conduct, the Deputy President reiterated

that despite the ‘somewhat confusing plea bargain’, she accepted Mr Bhatia’s version

of the event. It could be summed up as ‘Wrong place, wrong time, but with no ill

intent’.[38]

[38] Reasons, [41].

35         Noting that a finding of guilt with no conviction was recorded, and that the Tribunal

will rarely look behind a finding of guilt, the Deputy President said that in this case

she considered it appropriate to do so.[39]

[39] Reasons, [43]-[45].

36         As to the sentence imposed for the offence, the Tribunal had already noted that the

Magistrate had no concerns after the plea, did not impose any assessments or other

conditions, and apparently considered the offence to be at the lower end of the

scale.[40] The Deputy President also said:[41]

[40] Reasons, [38].

[41] Reasons, [46].

This is one of the rare cases where I have been prepared to accept the sworn evidence and really just remain a little confused as to how the charges were reached. He [Mr Bhatia] was found guilty and he was placed on a Good Behaviour Bond without any conviction. Once again it is hard to accept that if the Court had found the offending to be of the serious nature described, the Court would have imposed the very lenient sentence that it did. If the Court thought his behaviour was predatory or risky behaviour, it is unlikely that that would have been the outcome.

  1. The Tribunal’s finding that Mr Bhatia entered the female toilet by mistake, without

    sinister or predatory intent, was critical to the consideration of the remaining factors

    in s 14(3).[42] In relation to the likelihood of future threat to a child caused by the

    [42] Reasons, [48], [49], [50].

    applicant, the Deputy President did not think that Mr Bhatia posed any threat to

children, because she found that his offending was a mistake rather than calculated
criminal offending.[43]

[43] Reasons, [51].

38         The Tribunal was satisfied that it was not appropriate to refuse to give an assessment

notice to Mr Bhatia, having regard to s 14(3) of the WWC Act.

39 As to the reasonable person test under s 26C(2), the Tribunal was satisfied that a

reasonable person would allow Mr Bhatia to work in any kind of child related work,

supervised or unsupervised. The reasonable person would look at all of the

surrounding circumstances, see that Mr Bhatia had not offended before or since, see

the nature of the offence, and accept Mr Bhatia’s explanation for how it occurred.

The Tribunal also observed that the reasonable person:

… may also accept, as I have, that there are all different reasons why people

enter into plea deals and this is one of those cases where, I accept, Mr Bhatia entered into a plea deal out of expediency rather than because he would necessarily have received a criminal finding of guilt if the matter had proceeded. We will never know that and it is not my role to look into that, but the reasonable person would look to all of the circumstances.

  1. Also being satisfied that Mr Bhatia’s engagement in any type of child related work

    would not pose an unjustifiable risk to the safety of children, the Tribunal was

    satisfied that it was not appropriate to refuse to give an assessment notice under

    s 26C(2).

41 In relation to s 26C(3), the Tribunal considered that it was very much in the public

interest that Mr Bhatia continue all of the professional work and community work

that he had been doing, or wishes to do in the future, in light of his ‘splendid work

history’ and commendable community engagement. In all the circumstances the

Tribunal was satisfied that it was not appropriate to refuse to give an assessment

notice under s 26C(3).

Application for extension of time

  1. The Secretary’s originating motion was filed on 14 February 2018, 12 days after the

    expiry of the 28-day appeal period prescribed by s 148(2)(a) of the VCAT Act. He seeks an extension of time under s 148(5). While the discretion to extend time is at

    large, the authorities identify factors typically taken into account in order to do

    justice between the parties.[44] These factors include the length of the delay, any

    [44]             See for example Update Pty Ltd v Commissioner of State Revenue [2013] VSC 122, [29]; Muto v Secretary to the Department of Planning and Community Development (2013) 38 VR 293, [13].

    explanation for the delay, any prejudice to the respondent due to the delay, and

    whether there is an arguable case for leave to appeal. No single factor is

    determinative, although ordinarily time is not extended unless the applicant

    explains the delay and provides the Court with a good reason for excusing it.[45]

    [45]             Cooma Clothing Pty Ltd v Create Invest Develop Pty Ltd (2013) 46 VR 447, [15].

43         Here, the delay was short, and has caused no prejudice to Mr Bhatia in responding

to the proposed appeal.

44         However, the Secretary has neither explained the delay or provided any reason for

excusing it. The affidavit in support of the application merely set out a partial time

line of events and noted the expiry of the statutory time limit on 2 February 2018.

On that day, the WWC Unit wrote to Mr Bhatia’s solicitors to advise that the

Secretary intended to apply for leave to appeal but was not able to meet the deadline

to file the application. The letter advised that counsel had not yet been instructed to

prepare the necessary documents, due to ‘the lengthy process of obtaining

instructions’ and the WWC Unit’s decision not to brief counsel before receiving

instructions to appeal. The WWC Unit anticipated that the necessary documents

would be filed with the Court in the next two weeks, as indeed they were.

45         The Secretary’s approach to the time limit in this case is surprising and not

altogether satisfactory. He is the regulator under the WWC Act and is a frequent

applicant for leave to appeal under s 148 of the VCAT Act. High standards are set

for government parties who are expected to conduct themselves as model litigants.[46]

[46]             Secretary to the Department of Justice v XQH [2012] VSCA 72, [11] (XQH).

The Secretary, and the WWC Unit that supports him, should ensure that information

and advice is sought, decisions are made, and instructions are given in time for the

statutory time limit to be observed. Where that is not possible, the Court should be given a proper explanation for the delay and a reason for granting the indulgence

that is sought. Those were conspicuously absent here.[47]

[47]             In comparison with the ‘candid explanation’ given in XQH, [11].

46         The Secretary pointed out that the Court of Appeal routinely grants an automatic

14-day extension of time in respect of an application for leave to appeal from a

judicial member of the Tribunal.[48] He submitted that it would be ‘unusual and

[48]             As advised in the Court of Appeal’s Notice to Profession – Applications for extension of time under r 64.08

against the interests of justice’ for the Trial Division to refuse an extension of time

that would automatically have been granted by the Court of Appeal. However, the

Court of Appeal’s practice in this respect is due to the requirements for an

application for leave to appeal to be accompanied by a written case and several other

documents.[49] These requirements do not apply to an application for leave to appeal

[49] Supreme Court (General Civil Procedure) Rules 2015, r 64.03(1).

in the Trial Division, where the equivalent steps need not be taken until well after

the application is filed. I therefore cannot accept that the practice in the Court of

Appeal informs my consideration of whether an extension of time should be granted

in this case.

47         Those matters aside, I accept Mr Horan’s submission on behalf of the Secretary that

the most important consideration here is the merit of the questions of law in respect

of which the Secretary seeks leave to appeal. If the Tribunal’s decision involved an

error of law, the interests of justice would favour extending time in order that the

error can be corrected. I will therefore consider the merits of the Secretary’s

proposed appeal before determining whether time should be extended.

Leave to appeal

48 The Secretary seeks leave to appeal, on a question of law, under s 148(1) of the VCAT

Act.[50] Whether leave to appeal is granted depends on the justice of the particular case. The applicant for leave must identify a question of law for which there is a real

[50]             On 1 May 2018 the Justice Legislation Amendment (Court Security, Juries and Other Matters) Act 2017 (Vic) inserted a new s 148(2A) into the VCAT Act, that provides that the Trial Division of this Court may only grant leave to appeal if satisfied that the appeal has a real prospect of success. The new

or significant argument that the Tribunal was in error. It is also relevant whether the

question of law is one of general or public importance, and whether there is

sufficient doubt attending the question of law to justify a grant of leave.51

  1. I heard argument on the substance of the Secretary’s proposed appeal at the same

    time as hearing the applications for extension of time and for leave to appeal. It is

    convenient to consider whether leave to appeal should be granted in relation to each

    question of law identified in the Secretary’s proposed notice of appeal.

Question 1 Did the Tribunal err by making findings of fact that were inconsistent with

the finding of guilt?

  1. The first question of law identified in the Secretary’s proposed notice of appeal is

    whether the Tribunal erred in law in its consideration and application of s 26C of the

    WWC Act by making findings of fact that were inconsistent with the finding of guilt

    in relation to the offence of behaving in an offensive manner in a public place

    contrary to s 17(1)(d) of the Summary Offences Act, and accordingly making

    findings that were not open.

Submissions

51         The Secretary submitted that it is well established that an administrative decision-

maker may not impugn a conviction or a finding of guilt that forms the basis of the

decision maker’s authority to make a particular decision. A decision-maker will

impugn such a conviction where he or she makes findings that are inconsistent with

the essential factual basis of the conviction (or finding of guilt). A decision-maker

who impugns such a conviction, and proceeds to his or her conclusion on the basis

of facts inconsistent with the conviction, makes an error of law. A decision-maker is

not precluded from assessing the circumstances surrounding the commission of an

provision applies only to applications commenced on or after 1 May 2018: VCAT Act, s 170. This
application was commenced on 14 February 2018 and is not subject to s 148(2A).
  1. Secretary to the Department of Premier and Cabinet v Hulls [1999] 3 VR 331, [8]–[16]; see also Garde J’s

    summary in Zumpano v Banyule City Council [2016] VSC 420, [10].

SC:VL 16 JUDGMENT

Secretary to the Department of Justice and Regulation v Bhatia

offence, provided that the assessment does not impugn or ‘go behind’ the conviction

(or finding of guilt). Such an assessment may be necessary to enable the decision-

maker to make an assessment of, for example, the nature and gravity of the criminal

conduct. But the decision-maker must not proceed on a basis that is inconsistent

with the essential factual bases for the conviction (or finding of guilt).

52         These propositions were derived from a line of Federal Court authority in the

migration context: Minister for Immigration and Ethnic Affairs v Daniele,[52] Minister for

[52] (1981) 61 FLR 354 (Daniele).

Immigration and Ethnic Affairs v Gungor,[53] Minister for Immigration and Multicultural

[53] (1982) 63 FLR 441 (Gungor).

Affairs v SRT,[54] and Minister for Immigration and Multicultural Affairs v Ali.[55]

[54] (1999) 91 FCR 234 (SRT).

[55] (2000) 106 FCR 313 (Ali).

53         Recently, in Secretary to the Department of Justice and Regulation v LLF,[56] the Court of

[56] [2018] VSCA 155 (LLF).

Appeal accepted that these authorities apply to a review conducted by the Tribunal

under the WWC Act, where the conviction is the basis for the Tribunal’s jurisdiction.

In that case, it was held that the essential factual basis of the conviction is not able to

be reviewed, but the circumstances of the conviction can be reviewed for a purpose

other than impugning the conviction itself.[57] The Secretary submitted that this

[57]             LLF, [42]–[43].

analysis applies equally where, as here, a finding of guilt is the basis for the

Tribunal’s jurisdiction.

54         The Secretary submitted that the Tribunal fell into error by making findings that

were inconsistent with the essential factual basis of the finding of guilt against Mr

Bhatia, and by relying on those findings in determining that it was not appropriate

to refuse to him an assessment notice. He argued that Mr Bhatia’s plea of guilty

operated as a formal confession of every element necessary to constitute the

offence,[58] although he accepted that the plea did not necessarily amount to an

[58]             Relying on R v D’Orta-Ekenaike [1998] 2 VR 140, 146-7.

admission of every aspect of the police summary that was read to the Magistrates’

Court.

55         I invited further written submissions from the parties as to the elements of the

offence of behaving in an offensive manner in a public place and the essential factual

basis of a finding of guilt of that offence. The Secretary submitted that the physical

elements of the offence were (1) behaviour that is objectively, by reference to

community standards, offensive that (2) occurs in a public place. As to the mental

element, the Secretary submitted that there must be, at least, an intention to engage

in the relevant behaviour in circumstances that render it offensive to a reasonable

person.[59] Alternatively, if s 17(1)(d) were construed as creating a strict liability

[59]             Relying on Worcester v Smith [1951] VLR 316, 318; Ingles v Fish [1961] VR 607, 611 and Nelson v Mathieson (2003) 143 A Crim R 148, [13], [17].

offence, it would remain subject to the defence of honest and reasonable mistake of

fact.[60] Where such a defence is raised on the facts, the prosecution must prove

[60]             Relying on Proudman v Dayman (1941) 67 CLR 536, 540; CTM v The Queen (2008) 236 CLR 440, [8] and, in relation to a similar offence of offensive behaviour, Police v Pfeifer (1997) 68 SASR 285.

beyond reasonable doubt that the accused did not have an honest and reasonable,

but mistaken, belief that the behaviour was not offensive.

56         In this case, the Secretary submitted, the essential factual basis of the finding of guilt

against Mr Bhatia included the mental element, which was either that he

intentionally and knowingly entered the female toilets or, alternatively, that he did

not have an honest and reasonable mistaken belief that he was entering the male

toilets.

  1. By accepting Mr Bhatia’s version of events, the Secretary argued, the Tribunal made

    findings that were inconsistent with the essential factual basis of the finding of guilt

    against him. The Secretary emphasised several aspects of the Tribunal’s Reasons, in

    particular the observation that, if Mr Bhatia’s version was accepted, ‘it was difficult

    to see how any offence had occurred’ and the Deputy President’s statement that in

    this case it was appropriate to look behind the finding of guilt. The Secretary also

    drew attention to the Tribunal’s findings that Mr Bhatia’s presence in the female toilets was a ‘mistake’ or a ‘horrible mistake’,[61] and that his conduct was ‘a mistake

    [61] Reasons, [29], [31], [32].

    (of entering the wrong toilet block without sinister intent)’[62] and ‘a mistake rather

    [62] Reasons, [49].

    than calculated criminal offending’.[63]

    [63] Reasons, [51].

  2. These findings were material to the Tribunal’s ultimate findings that it was not

    appropriate to refuse to give Mr Bhatia an assessment notice, under each subsection

    of s 26C. Hence, the Secretary submitted, the Tribunal was in error.

59         Mr Bhatia submitted that the Tribunal did not impugn the finding of guilt, but

accepted it as enlivening the Tribunal’s jurisdiction. The Tribunal was permitted,

indeed required, to have regard to the circumstances surrounding the offence and

could examine the actual facts of Mr Bhatia’s conduct without undermining the

finding of guilt. He drew a distinction between a plea of guilty to a summary

offence and a jury’s verdict at the end of a contested trial. The former does not

involve any adjudication of disputed issues of fact, and so is not comparable to a

jury verdict.[64] He pointed out that the High Court has acknowledged, in Meissner v

[64]             Each of Daniele, Gungor and SRT involved a jury verdict. By contrast, LLF involved a plea of guilty.

R,[65] that a person may enter into a guilty plea ‘for all manner of reasons’ and

[65] (1995) 184 CLR 132, 157 (Dawson J).

submitted that the Tribunal was entitled to consider his reasons for pleading guilty.

60         As to the elements of the offence, Mr Bhatia submitted that they were (1) that the

behaviour the subject of the charge took place in a public place and (2) that it was

objectively offensive. Based on the authorities of Police v Pfeifer[66] and Nelson v

[66] (1997) 68 SASR 285 (Pfeifer).

Mathieson,[67] he submitted that intention was not an element of the offence, although

[67] (2003) 143 A Crim R 148.

the defence of honest and reasonable mistake would be available to an accused.

Although the Tribunal found that Mr Bhatia had entered the female toilets by

mistake, it had not found that the mistake was reasonable, and so its finding was not

inconsistent with the finding of guilt.

Consideration

  1. The Tribunal’s review jurisdiction in this case was invoked by Mr Bhatia under

    s 26(1)(d) of the WWC Act, because of the Secretary’s decision to revoke his

    assessment notice and give him a negative notice following a category C re-

    assessment. The original charges were still pending at the time of the Secretary’s

    decision and when Mr Bhatia applied to the Tribunal for review of the decision. It

    was not the case, therefore, that the finding of guilt recorded against Mr Bhatia on 18

    July 2018 was the basis of or the trigger for the Tribunal’s jurisdiction. Had the

    charges still been pending when the Tribunal heard the application, the Tribunal

    would have had no choice but to form its own view of the alleged offending conduct

    on the evidence before it. However, by the time the application was heard by the

    Tribunal in November 2017, Mr Bhatia had pleaded guilty to one, amended charge.

    The Tribunal’s task was to determine, in accordance with s 26C, whether it would be

    appropriate to refuse to give an assessment notice to Mr Bhatia, in the circumstances

    that applied at the time of the hearing – including the finding of guilt.

62         Although the finding of guilt did not form the basis of the Tribunal’s jurisdiction, it

was conclusive as to Mr Bhatia’s guilt of the offence and the sentence imposed by the

Magistrates’ Court.[68] The Tribunal could not review the essential factual basis for

the finding or determine the review on the basis that Mr Bhatia should not have been

found guilty.[69] It was, however, able to receive evidence of the circumstances of the

offending and was able to make its own findings about those circumstances –

indeed, it was obliged to do so in order to make findings about the nature and

gravity of the offending.[70] The Tribunal’s findings could differ from the police

summary, but could not be inconsistent with the finding of guilt and the essential

basis for it.

[68]             Gungor, 446, 450 (Fox J), 468-9 (Sheppard J); SRT, [23]-[25]; LLF, [42].

[69]             Daniele, 358 (Fisher and Lockhart JJ); Gungor, 445-6 (Fox J), 469 (Sheppard J); LLF, [42].

[70]             Daniele, 358-9 (Fisher and Lockhart JJ), 362-3 (Davies J), LLF, [42].

63         As Fox J recognised in Gungor, this may be a difficult line to draw:[71]

On occasion the border line of proper inquiry or of legitimate consideration may be difficult to determine. If the problem arises in practice, it will have to be met. However, the case is probably a rare one where the line between what can be taken into account and what cannot becomes too refined without there having been a sustained attack on the conviction, or a determined presentation of evidence running counter to it. In either case the Tribunal is put on notice, and can control proceedings in such a way as seems appropriate to it.

[71]             Gungor, 449 (Fox J). See also Sheppard J at 469.

This case is one of the rare ones. The difficulty in drawing the line here is

contributed to by the ‘somewhat confusing plea bargain’, which saw Mr Bhatia

plead guilty to an amended charge, without any corresponding amendment to the

police statement of alleged facts. While this may have seemed a reasonable way to

deal with the charge in a busy Magistrates’ Court, more attention might have been

given by Mr Bhatia and those advising him to the interaction between his guilty plea

and his pending application to the Tribunal.

64         What, then, is the essential factual basis of the offence of which Mr Bhatia was found

guilty? The answer to that question requires identification of the elements of the

offence of behaving in an offensive manner in a public place, contrary to s 17(1)(d) of

the Summary Offences Act, a summary offence that covers a wide range of conduct.

65         The parties were agreed on the physical elements of the offence. The first element is

behaviour that is objectively offensive, by reference to community standards. The

second element is that the behaviour occurs in a public place. There was no dispute

here about the second element: it was plain that the female toilets that Mr Bhatia

entered are a public place.

66         As to the first element, the totality of the conduct that was alleged against Mr Bhatia

in the police summary was objectively offensive. However, the Tribunal accepted

that he had not deliberately looked into the complainant’s cubicle and had not made

any sexual comment to her. The Tribunal found only that Mr Bhatia had entered the

female toilets by mistake, under the influence of alcohol but with no predatory or ill

intent, had looked around for a urinal and had spoken with the complainant, before

leaving without incident after she told him to ‘get out’. The parties accepted that the

entry and presence of a man in the female toilets within a public toilet block was

SC:VL 21 JUDGMENT

Secretary to the Department of Justice and Regulation v Bhatia

capable of being found to be offensive, particularly at night.[72] The Tribunal’s

findings were therefore consistent with the physical elements of the offence.

[72]             Respondent’s supplementary submission dated 3 August 2018, [12]; Applicant’s further submissions

67         The mental element of the offence is, however, in dispute. The Secretary’s primary

contention was that s 17(1)(d) of the Summary Offences Act requires, at least, an

intention to engage in the behaviour the subject of the charge, if not an intention to

offend. Mr Bhatia submitted, in reliance on the South Australian decision of Pfeifer,

that intention was not an element of the offence, but that the defence of honest and

reasonable mistake was available. I understood this to be a submission that the

mental element of the offence was absence of an exculpatory belief, in the form of an

honest and reasonable, but mistaken, belief that the behaviour was not offensive, or

did not occur in a public place.[73]

[73]             The ‘defence’ of honest and reasonable mistake was explained in Director of Public Prosecutions v

68         The starting point must be that the presumption that a statute does not impose

criminal liability unless a guilty state of mind is proved. That is, however, only the

starting point: ‘It is one thing to say that mens rea is an element of an offence; it is

another thing to say precisely what is the state of mind that is required’.[74]

[74]             He Kaw Teh v The Queen (1985) 157 CLR 523, 568 (Brennan J) (He Kaw Teh).

69         Whether the offence requires proof of intent to engage in the conduct alleged, as is

generally presumed, or the absence of an exculpatory belief, turns on the language of

the statute, its subject matter and purpose.[75] The language of s 17(1)(d) itself

provides no indication as to the mental element of the offence, and so it is necessary

to look to the broader statutory context.

[75]             He Kaw Teh, 576 (Brennan J); Pfeifer, 291.

70         The Summary Offences Act is not the most coherent of statutes. At the time of its enactment, it was a miscellaneous collection of offences applying to subject matter as

diverse as public order, contraceptives, tattooing of juveniles and homing pigeons.[76]

Over the time it has been in force it has been amended numerous times, and it is

now showing signs of wear. Its subject matter remains diverse. Many of the original

offences remain in force, and have an important and ongoing role in maintaining

public order. To those offences have been added a number of new offences,

including offences dealing with sexting,[77] food and drink spiking,[78] and assaulting

emergency workers and health practitioners.[79] Mixed with these are offences that

reflect concerns of times past: it is still an offence against the Summary Offences Act

to fly a kite to the annoyance of any person,[80] to drive a goat harnessed to a vehicle

through a public place,[81] and to ensnare a homing pigeon.[82]

[76] Summary Offences Act 1966, as enacted, s 1.

[77] Summary Offences Act, Pt 1, Div 4A.

[78] Summary Offences Act, Pt 1, Div 4B.

[79] Summary Offences Act, ss 51 and 51A.

[80] Summary Offences Act, s 4(d)(i).

[81] Summary Offences Act, s 8(c).

[82] Summary Offences Act, s 46.

71 Both parties pointed to different aspects of the Summary Offences Act to support

their contended mental element for s 17(1)(d). The Secretary relied on s 18(2), which

provides that an offence against s 18(1) is a strict liability offence, and submitted that

the absence of any such provision in s 17 is a telling indication that intention is

required. Mr Bhatia pointed out that s 17(1)(d) is an offence in respect of which a

police officer can issue an infringement notice,[83] which tends to indicate that it is a

strict liability offence.

[83] Summary Offences Act, s 60AA(1A). Section 60AA(1AB) confers a similar power on a protective

72 As I have outlined, the Summary Offences Act contains a jumble of offences that

have been amended and revised over more than 50 years, and it is hard to discern

any clear legislative intent from the language of isolated provisions. Two themes do

emerge, however, similar to those identified by Doyle CJ in his examination of the

Summary Offences Act 1953 (SA) in Pfeifer.

73         The first theme is that, for a disparate range of offences in the Summary Offences

Act, Parliament has identified a state of mind that must be established as an element

of an offence, or that may be a defence. Some offences must be committed wilfully.[84]

Some offences require knowledge of a state of affairs.[85] Lack of knowledge or

consent is a defence to others.[86] Intent is specified as an element of some offences,[87]

while absence of intent to defraud is an element of the defence to passing a valueless

cheque.[88] Other provisions – including s 17(1)(d) – simply describe the conduct that

constitutes the offence, without reference to any state of mind. This may be an

indication that Parliament meant to criminalise the conduct identified in those

provisions even if the accused did not intend it or know that it would have the

proscribed effect.

[84] Summary Offences Act, ss 8(i), 9(c)-(e), 21, 52(1A).

[85] Summary Offences Act, ss 30(1), 31, 41H(2), 34(1), 51A(1), 51A(2), 53, 54.

[86] Summary Offences Act, ss 10(2), 27(3), 30(2), 33.

[87] Summary Offences Act, ss 41A-41C, 41DA, 49B, 49C, 50A(5).

[88] Summary Offences Act, s 37(2).

74 The second theme that emerges from the Summary Offences Act is that many of its

provisions are directed to maintaining public order and a tolerable standard of

conduct in public spaces. As Doyle CJ observed in Pfeifer:[89]

There is … a common thread of punishing and deterring behaviour likely to

annoy, disturb or upset average members of the community. Expressed differently, the relevant provisions can be regarded as requiring conformity to standards accepted by a wide range of people in society. The provisions operate on actions and conduct likely to occur in everyday life.

[89]             Pfeifer, 291 (Doyle CJ, Debelle and Lander JJ agreeing).

75         Bringing these two themes together, I have reached the same conclusion about the

mental element in s 17(1)(d) of Victoria’s Summary Offences Act that the Full Court

of the Supreme Court of South Australia reached in relation to the equivalent

provision in the Summary Offences Act 1953 (SA):[90]

It appears to me to be a provision intended to protect members of society from disturbance and annoyance through offensive behaviour, intended to prevent the sort of disputes and disturbances that might arise if such behaviour is not prevented by law with the consequence that members of society react to it or resist it in other ways. To convict only those who intentionally or knowingly offend will achieve a good deal, but does not go that extra step of requiring members of society to take care to ensure that they do not breach generally accepted standards of behaviour.

[90]             Pfeifer, 292 (Doyle CJ, Debelle and Lander JJ agreeing).

76         On that basis, I conclude that intent or knowledge is not an essential element of the

offence in s 17(1)(d). The offence will be established on proof (or admission) that the

accused was not honestly and reasonably mistaken about the circumstances in which

the conduct was offensive or the fact that it occurred in a public place. There is an

evidentiary onus on an accused person to raise the ground of honest and reasonable

mistake. Once that occurs the prosecution must prove, beyond reasonable doubt,

the absence of an exculpatory belief.[91]

[91]             Director of Public Prosecutions v Stanojlovic [2017] VSC 540, [26]; Stanojlovic v Director of Public (2018) 84 MVR 386, [45].

77         This conclusion does not conflict with existing Victorian authority, none of which is

directly on point. In Nelson v Mathieson,[92] which concerned a charge of offensive

behaviour in a public place, Nathan J held that it was not necessary for the

prosecution to prove that the accused intended to be offensive. That decision sits

comfortably with the earlier Victoria authorities of Worcester v Smith[93] and Ingles v

Fish.[94] In both of those cases it was held that, in order for behaviour to be ‘offensive’,

it had to be ‘calculated to wound the feelings, or arouse anger or resentment or

disgust in the mind of a reasonable person’.[95] Neither case involved any

consideration of the mental element of the offence; the question in each was whether

the alleged behaviour was ‘offensive’. In that context, I understand the words

‘calculated to’ were used in the sense of ‘likely to’ rather than ‘intended to’.[96]

[92] (2003) 143 A Crim R 148, [13], [17].

[93] [1951] VLR 316 (Worcester).

[94] [1961] VR 607 (Ingles).

[95]             Worcester, 318; Ingles, 611.

[96]             O’Sullivan v Lunnon (1986) 163 CLR 545, 549 (Gibbs CJ), 552-3 (Brennan J); Howard v Gallagher (1989) 85

78         I have also considered the decision of the Northern Territory Court of Criminal

Appeal in Pregelj v Manison,[97] in which the offence of offensive behaviour in view of

a public place, contrary to s 47(a) of the Summary Offences Act (NT), was held to require proof of intent to commit the act in the view of a person in a public place, or

foresaw it as a possible consequence of the act.[98] That conclusion was based

squarely on s 31 of the Criminal Code (NT), which excuses a person from criminal

responsibility for an act, omission or event ‘unless it was intended or foreseen by

him as a possible consequence of his conduct’. There is no equivalent provision that

applies here, and so the decision provides no guidance in construing s 17(1)(d).[99]

[97] (1987) 88 FLR 346 (Pregelj).

[98]             Pregelj, 360-1 (Nader J), 362-3 (Kearney J), cf 367-9 (Rice J).

[99]             Pfeifer, 290 (Doyle CJ, Debelle and Lander JJ agreeing).

79 Having reached the conclusion that the mental element of the offence in s 17(1)(d) is

absence of an honest and reasonable but mistaken belief that the conduct is not

offensive or is not in a public place, I can return to the findings made by the Tribunal

about Mr Bhatia’s offending. The Tribunal accepted Mr Bhatia’s account of what

took place that night, including that he entered the female toilets by mistake. There

is a clear inference that the Tribunal accepted that he made an honest mistake. The

Tribunal did not find, however, that Mr Bhatia’s mistake was a reasonable one. By

pleading guilty to the amended offence, and in his reflections in his evidence to the

Tribunal, Mr Bhatia acknowledged that his presence in the female toilets was not

reasonable. He admitted that he was affected by alcohol, having drunk more than

he was used to. He did not dispute that the male and female toilets were ‘clearly

signed with their relevant gender’, as alleged in the police summary. He realised

that it would have been a ‘horrible experience’ for the complainant, and was genuine

in his understanding that she would have felt incredibly confused by his presence in

the female toilet at that hour of the night.[100] He ‘showed a complete understanding

of her position’.[101] These findings are all consistent with the absence of an

exculpatory belief.

[100] Reasons, [36].

[101] Reasons, [50].

80         On that basis, I conclude that the Tribunal did not make findings of fact that were

inconsistent with the essential factual elements of the offence of which Mr Bhatia

was found guilty, and did not impugn the finding of guilt against him. No error is

established in relation to the first question of law raised by the Secretary’s proposed

appeal.

Extension of time and leave to appeal reprise

81         Returning to the questions of extension of time and leave to appeal, I observe that

the issues raised by the Secretary in this Court were not the subject of any

submission to the Tribunal. This was, in my view, a regrettable omission. It would

no doubt have assisted the Deputy President to have been reminded of the

borderline between proper inquiry into the circumstances of the offending and legal

error, and to have had the assistance that I had in identifying the essential factual

elements of the offence in s 17(1)(d).

82         There are restrictions on raising a point on appeal that was not raised below, for

sound reasons.[102] These restrictions apply to appeals from the Tribunal, as much as

to any other appeal.[103] Even when a new point could not have been met by further

evidence at trial, it may not be in the interests of justice to allow a new point to be

raised on appeal if it would require a further trial.[104]

[102]            Whisprun Pty Ltd v Dixon (2003) 200 ALR 447, [51] (Gleeson CJ, McHugh and Gummow JJ) (Whisprun); Vlahos Pty Ltd v Vlahos [2017] VSCA 166, [49].

[103]            Able Demolitions and Excavations Pty Ltd v Yarra Ranges Shire Council (2008) 160 LGERA 439, [42]; Risi Pty Ltd v Pin Oak Holdings Pty Ltd [2017] VSCA 317, [74].

[104]            Whisprun, [51].

83         However, Mr Bhatia did not make any complaint that the issues raised in the

Secretary’s proposed appeal were not raised below, and neither party made

submissions on whether those issues could have been met by further evidence or

whether it would be the interests of justice to grant leave to appeal on a question not

raised below. Although it was not argued before the Tribunal, the first question of

law identified in the Secretary’s proposed notice of appeal raised a real and

significant argument of importance. I will therefore make orders extending time,

and granting leave to appeal in relation to the first question of law. For the reasons I

have given, however, I will dismiss the appeal.

Question 2 Did the Tribunal wrongly proceed on the basis that the parties had invited

it to reach its own conclusions on the facts?

84         The second question of law in the proposed notice of appeal is whether the Tribunal

erred in law or denied procedural fairness to the Secretary, by proceeding on an

erroneous basis that the parties had invited the Tribunal to reach its own conclusions

on the facts of the offending (as opposed to the facts concerning the basis on which

Mr Bhatia’s plea of guilty was made and accepted), and accordingly by making

findings that were not open.

85         Mr Horan rightly acknowledged in argument that this question of law was tied up

with the first question. The Tribunal was entitled to make its own findings about the

offending conduct and the circumstances in which it occurred.[105] I have found that

the Tribunal did not make findings that were inconsistent with the essential factual

elements of the offence and that the findings that it made about Mr Bhatia’s

offending conduct were open to be made.

[105] As discussed at [62] above.

86         As to the complaint of want of procedural fairness, it appears from the transcript of

the hearing below that counsel for the Secretary anticipated that the Tribunal would

make its own findings about the offending.[106] At one point he submitted ‘if you

accept the account by the applicant then it puts the categorisation of the offending in

a somewhat different light than if you accept the summary that was read out’.

Having reviewed the transcript of the hearing I am not persuaded that the Tribunal

proceeded on a wrong understanding of the Secretary’s case.

[106]            Ventrice affidavit, exhibit GAV-1, pp 241-2.

87         In addition, the Secretary had every opportunity to respond to the case put by Mr

Bhatia before the Tribunal. It was clear throughout that he disputed critical facts

alleged in the police summary, and that his case was that he had entered the female

toilets by mistake and with no ill intent. The Secretary could have, but did not, call

evidence to contradict Mr Bhatia’s account.

  1. I do not consider that the Secretary’s second question of law raises a real or

    significant argument that warrants leave to appeal. I will therefore refuse leave to

    appeal in relation to the second question.

Disposition

89         I will make orders to the following effect:

(a) The Secretary is granted an extension of time in which to commence the

proceeding, to 14 February 2018;

(b) The Secretary is granted leave to appeal in respect of the first question of law

in his proposed notice of appeal;

(c) The appeal is dismissed;
(d) The application for leave to appeal is otherwise dismissed.

90         I will hear the parties as to the costs of the proceeding.

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On 17 May 2017 the Tribunal granted his application for an extension of time in which to file his application: Ventrice affidavit, [13].

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of the Supreme Court (General Civil Procedure) Rules 2015 that applied for 12 months from 1 May 2017. The practice was adopted in respect of applications for leave to appeal, including those made under s 148 of the VCAT Act.

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dated 10 August 2018, [16], fn 27.

Stanojlovic [2017] VSC 540, [26] as follows: ‘It is a principle at common law that an honest and

reasonable, but mistaken, belief in a set of facts which, if they existed, would have made the defendant innocent, provides a ground of exculpation. The evidentiary onus of raising the ground is on the defendant. Once that occurs, the legal onus lies on the prosecution to prove beyond reasonable doubt the absence of an honest and reasonable belief.’ See also, Stanojlovic v Director of Public (2018)

84 MVR 386, [45].

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services officer in respect of a ‘designated place’.

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ALR 495, 497-8.

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