© 2026 Zoe. All rights reserved.
Zoe is a legal information platform. Always consult the Federal Register of Legislation for authoritative text.
[2004] VSC 247
Supreme Court of Victoria
2004-04-22
Redlich J
Original judgment source is linked above.
[2004] VSC 247
Bail application - Trafficking in a drug of dependence - Section 4(4)(a) Bail Act 1997 - Financial and emotional hardship to Applicant's family - Whether "sufficient cause". Section 4(2)(d) Bail Act 1997 - "Unacceptable risk" - Degree of risk and standard of proof - Time likely to elapse before charges are heard.
(a) with an indictable offence that is alleged to have been committed whilst he was at large awaiting trial for another indictable offence
the court shall refuse bail unless the accused person shows cause why his detention in custody is not justified and in any such case where the court grants bail the court shall prescribe and transmit a statement of reasons for making the order."
"A court shall refuse bail if the court is satisfied - (1) That there is an unacceptable risk that the accused person if released on bail would commit an offence whilst on bail."
Onus where a similar offence committed whilst on bail
"In my view, it is wrong to approach the issue under s.8(2) and s.22(1)(c) on the basis of the elimination of risk. The correct question to ask is whether the prosecution has satisfied the Court that on the evidence before it there is a real likelihood of the applicant committing an offence while released on bail, although in this connection, likelihood does not mean more likely than not (see the explanation by Deane J in Tillmanns Butcheries Pty Ltd v Australasian Meat Industry Employees' Union [1979] FCA 85; (1979) 42 FLR 331 at 346-8, 27 ALR 367 at 380-382."[14]
"The issue of detention by reason of unacceptable risk is an issue which must be balanced with the likelihood the allegations against an accused man then brought before a court in the near future. The question of unacceptable risk is to be judged according to proper criteria, one of which is the length of delay before trial; that is, although the risk might be objectively the same at different times, the question of unacceptability must be relative to all the circumstances, including the issue of delay."[17]
[2] [1994] MC 166 per Mandie J.
[5] [2001] VSC 237 at [60-66].
[7] (1999) 107 A Crim R 358; [1999] FCA 921 per Gyles J at [56].
[9] [1974] AC 207 at 212.
[10] (1989) 18 NSWLR 319 at 325 per Gleeson CJ.
[12] [2002] VSC 321 per Nettle J.
[13] Supra [1999] FCA 921 per Gyles J.
[15] [2002] VSC 312 per Kellam J. at [41].
Haidy
DPP [2004] VSC 247
(1979) 42 FLR 331
(1989) 18 NSWLR 319