Van Doorn v The Queen

In *Van Doorn v The Queen*, the High Court of Australia considered an appeal from a decision of the Supreme Court of Victoria. The appellant, Van Doorn, had been convicted of murder and appealed against that conviction. The central dispute concerned the admissibility of certain evidence during the trial.

The primary legal issue before the High Court was whether the trial judge had erred in admitting evidence of the appellant's prior convictions. Specifically, the court had to determine if this evidence was improperly used to suggest that the appellant had a propensity to commit criminal acts, thereby prejudicing the jury against him, or if it was admissible for a legitimate purpose, such as demonstrating a common pattern or system in the commission of offences.

Hayne J, delivering the judgment of the High Court, analysed the principles governing the admission of evidence of prior convictions. His Honour referred to the general rule that such evidence is inadmissible if its sole purpose is to show a disposition to commit crime. However, he noted that exceptions exist where the evidence has a legitimate probative value, such as establishing a common design or system. In this instance, Hayne J found that the evidence of prior convictions was admitted for the improper purpose of demonstrating the appellant's propensity for criminal behaviour, and that its prejudicial effect outweighed any legitimate probative value. The jury was therefore invited to infer guilt from past conduct rather than from the evidence relating to the specific charge.

Consequently, the High Court allowed the appeal, quashed the conviction, and ordered a new trial.