© 2026 Zoe. All rights reserved.
Zoe is a legal information platform. Always consult the Federal Register of Legislation for authoritative text.
[1999] VSCA 227
Court of Appeal (Vic)
1999-12-09
BROOKING, CHARLES and CHERNOV, JJ.A.
Original judgment source is linked above.
EVIDENCE - Credibility of defendant's evidence - Alleged discrepancy with case put to plaintiff in cross-examination - Jury to determine whether breach of rule in Browne v. Dunn.
"2. The learned trial Judge failed to give adequate directions to the jury in relation to a breach by the respondent's counsel of the rule in Browne v. Dunn in his cross-examination of the appellant, Jullian Beattie.
3. The learned trial Judge erred in directing the jury that it should determine whether the respondent's counsel was in breach of the rule in Browne v. Dunn having regard to the manner in which he cross-examined the appellant, Jillian Beattie, and in the light of the evidence given by the respondent both in evidence-in-chief and in cross-examination.
4. The learned trial Judge erred in failing to direct the jury that counsel for the respondent was, in fact, in breach of the rule of Browne v. Dunn having regard to his cross-examination of the appellant, Jillian Beattie, and in the light of the evidence given by the respondent both in evidence-in-chief and in cross-examination."
"It is, I suppose, a matter of impression and interpretation as to whether what counsel put to the police officers sufficiently conveyed the substance of the evidence subsequently given by the appellant and Aldous. The learned judge read the relevant passages to the jury and left it to their judgment. I cannot see much substance in the point but it was a matter for the jurors who heard the evidence and the cross-examination. I do not think that the learned judge can be criticised for leaving it for their consideration."
"What the learned trial judge did was to give a full and detailed explanation as to the rule of practice and the issues that arose in the case out of the three particular matters which he had isolated by topic. In my judgment, the learned trial judge did not misstate any fact. He accurately put the matters upon which there had been cross-examination of the police officers, and those upon which there had been no cross-examination. In that he emphasised certain aspects and indicated the importance of those matters so far as the jury's deliberations were concerned, was to do no more than assist the jury in their essential task of assessing the evidence and how to fit those matters into the jury's fact-finding function."
Legoe, J. observed at 28 that he could not detect any error in the charge. He added, "That the learned trial judge may have emphasised certain matters as being of importance was to say no more to the jury than merely to draw their attention to their very important task of determining the facts." Bollen, J. concurred in the judgment of the Chief Justice.
"If the jury is satisfied that material allegations were later made by an accused which were not put to the relevant witness, that failure does not compel the jury to any particular conclusion and does not relieve the prosecution of its obligation to prove the ingredients of the charge. In the case of a glaring and obvious omission the jury might ask whether such matters indicated recent invention of those material allegations by the accused (or his witnesses)." (My emphasis)
"I think then what I need to say to the jury is for the defendant it is argued that in fact that did not constitute a new version, that those answers did not in fact constitute a departure from the defence case, and that's really ultimately the critical thing."
"Now, of course, the first question is was that version of the facts put to Mrs Beattie, that is that Dr Ball expressly asked her about birth defects and in response she said there were none."
"As I say, your first question is to determine whether in fact the case put to Mrs Beattie differed from the case revealed in that last answer of Dr Ball."
The judge then went on to deal with the inferences which the jury might draw if they were satisfied that there was a discrepancy.
"It is ultimately a question for the jury as to whether they take that as a different case from the one that had otherwise been presented up to that time."
"He then started asking things like family history - things like, sorry, name and address and date of birth and any allergies, went on to some family history, my own personal history, and when we started talking mostly about the family history, I pulled out my piece of paper ...".
Other Notes: _________________________________
________________________________________________
________________________________________________".
"It is correct, is it not, doctor, that where you have a new patient that would be a critical matter with which to obtain instructions about?---What, the family history you're saying? Yes?---Yes. And indeed it is correct to say, is it not, that if she hadn't told you about this family history and you were carrying out a routine first interview you would normally ask a new patient about any abnormal history or genetic defect?---Yes. Did you ask her?---Yes, I did. You did ask her?---Yes. I see?---Yes. And what, she said there were none?---She must have. She didn't tell me. She what?---She didn't tell me there was a family history. You asked her whether there was any family defect or abnormality and she said to you there was none?---Yes."
Beattie
Ball [1999] VSCA 227