The Queen v Ahmad [2011] NTSC 71
PARTIES: The Queen
v
AHMAD, Ahmad
TITLE OF COURT: SUPREME COURT OF THE NORTHERN TERRITORY
JURISDICTION: SUPREME COURT OF THE TERRITORY EXERCISING CRIMINAL JURISDICTION
FILE NO: 21042169
DELIVERED: 22 September 2011
HEARING DATES: 19 and 20 September 2011
RULING OF: BLOKLAND J
CATCHWORDS:
CRIMINAL LAW – MIGRATION ACT (CW) – question of law – were the 49 passengers persons to whom subsection 42(1) applied – question is directed to construction of s232A Migration Act – does the inclusions of s 42(1) within s232A create a requirement ‘travel to Australia’ that the Crown must prove – what is travel to Australia for the purpose of s 42(1) – s 42(1) as it applies to s 232A requires proof that the subject persons travel to Australia – there is a requirement that they cross the outer boundary of Australia’s Territorial Sea – Crown will be unable to prove an offence against s 232A in this case.
Can the acts of facilitation committed outside of the Australian Contiguous zone constitute the offence under s 232A (1) – would application of the Migration Act beyond the contiguous zone breach international law – would criminalising the acts of facilitation beyond the contiguous zone breach international law – construction of s 232A (1) does allow general and wide spread extra-territorial reach in terms of acts of facilitation – by their nature ‘facilitating’ and ‘organising’ are likely to occur outside of Australia – acts of facilitation need not be shown to be within the territorial sea.
Do people seeking asylum from prosecution have a lawful right to come to Australia – not necessary to answer this question for the purpose of this trial.
Migration Act (CW) s 5, s 42(1), s 228A, s 232A, s 232A(1), s 245A, s 245B, s 245C
Acts Interpretation Act (CW) 15B(1)(4)
Evidence Act (NT) s 26L,
Seas and Submerged Lands Act (CW) s 7, s 10A, s 13A,
Crimes Act (CW) s 50BA, s 50BC
Tran v The Commonwealth (2010) 187 FCR 54; applied
Barcelo v Electrolytic Zinc Co of Australasia Ltd (1932) 48 CLR 391; Bloxam v Favre (1883) 8 P.D. 101; XYZ v The Commonwealth (2006) 227 CLR 532; Zachariassen v The Commonwealth (1917) 24 CLR 166;
followedDirector of Public Prosecutions (NT) v WJI (2004) 219 CLR 43; R v LK (2010) 241 CLR 177; Nguyen v R [2005] WASCA 22; considered
Joyce v DPP [1946] AC 347; Minister of Immigration and Multicultural and Indigenous Affairs v QAAH of 2004 (2006) 231 CLR 1; Payara v The Queen, Ruling of 12 September 2011; Rutu v Dalla Costa (1997) 139 FLR 265; referred to
“Problems of Jurisdiction and Law Enforcement Against Delinquent Vessels” (1986) 3 ICLQ 320, Professor Ivan Shearer,
REPRESENTATION:
Counsel:
Defendant: Alistair Wyvill SC, Professor Les McCrimmon, Ian Read
Respondent: Mr Batten
Solicitors:
Defendant: Northern Territory Legal Aid Commission
Respondent: Commonwealth Director of Public Prosecutions
Judgment category classification: B
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- The Queen v Ahmad [2011] NTSC 71
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CaseChat Overview and Summary
The court held that the Crown must prove the non-citizens "travelled to Australia" under s 42(1) of the Migration Act, as it was expressly incorporated into s 232A. The court also found that s 232A has extra-territorial reach and is capable of applying beyond the territorial sea and the contiguous zone. However, given the conclusion on the first issue, the court declined to answer whether acts of facilitation committed outside of the Australian Contiguous Zone could constitute an offence under s 232A(1). The court found that the group of "five or more people" were not people to whom s 42(1) Migration Act applied within s 232A Migration Act.
In conclusion, the court ruled that the Crown must prove the non-citizens "travelled to Australia" under s 42(1) of the Migration Act, and that s 232A has extra-territorial reach and is capable of applying beyond the territorial sea and the contiguous zone. The appellant's appeal was dismissed.
Orders
Orders of the court
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Background
Background to the litigation
Evidence
Evidence Before The Court
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Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
Section 42(1) Migration Act (CW) provides:(1)Subject to subsections (2), (2A) and (3)[5], a non-citizen must not travel to Australia without a visa that is in effect.(i)Does the inclusion of s 42(1) Migration Act with s 232A create a requirement “travel to Australia” that the prosecution must prove? The Crown submits notwithstanding the reference to s 42(1) in s 232A Migration Act, all that is required to be proven by way of a circumstance, is that at least five of the non citizens did not have a valid visa to come to Australia. It is submitted there is no need to prove “travel to Australia” as that term is used in s 42(1). The Crown argues the physical and fault elements for s 232A Migration Act (CW) are as follows:(a)The accused(D) facilitated to bringing to Australia of a group of 5 or more people (physical/conduct);(b)D did so intentionally (fault/intention);(c)At least 5 of the persons had no lawful right to come to Australia – that is to say, they were not citizens and did not have a visa that was in effect (physical/circumstance);(d)D was reckless as to the fact that at least 5 of the persons had no lawful right to come to Australia – that is to say, they were non-citizens who did not have a visa that was in effect (fault/recklessness). The Crown’s analysis is that ‘recklessness’ is the fault element applying to the physical element (c), a “circumstance”. The “circumstance” on this argument is referrable to s 42(1) Migration Act. Section 42(1) however does not state merely that the persons “were not citizens and did not have a visa that was in effect”. It states “a non-citizen must not travel to Australia without a visa that is in effect”. Having expressly incorporated s 42(1) Migration Act as part of the definition of the offence, in accordance with long held rules on the interpretation of penal provisions, the provision must be strictly construed. Although recklessness is indeed the express fault element[6] as to the accused’s mental state vis a vis the status of the people, that status must first be determined by application of s 42(1). The status of the people concerned, must be determined by force of s 232A Migration Act in accordance with s 42(1). The prohibition in s 42(1) is not merely not having a visa in effect, but not travelling to Australia without one. It has been argued s 42(1) represents a requirement that is not a physical element in the sense the High Court analysed the offence of conspiracy in R v LK.[7] There the plurality judgement held the physical element of conduct involving the entry into the agreement was the relevant conduct that was criminalised. The specifications of what would be expected to be amount to an agreement were all considered referrable and subsumed in the physical element of the criminalised agreement. To import those requirements or specifications would produce highly technical and artificial “elements” of the offence.[8] In any event, citing Director of Public Prosecutions (NT) v WJI,[9] the plurality judgement adopted the observation “that the operation of those provisions of the Codes dealing with general principles can be worked out only by specific solutions of particular difficulties raised by the precise facts of given cases”. In my view the reasoning of R v LK does not exclude treating here the words “travel to Australia” as at least a “requirement” that must be proved. It may be regarded a physical element, or as I prefer, a requirement that must be proven without necessity of proof of a separate fault element.