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[2002] VSC 531
Supreme Court of Victoria
2002-11-26
Byrne J
Original judgment source is linked above.
[2002] VSC 531
MAGISTRATES COURTS - Short service of criminal process - Whether Court might proceed ex parte Magistrates' Court Act 1989 ss.34, 41(2). CRIMINAL LAW - Driver's blood test - Certificate of Analysis - Certificate short served - Whether admissible in evidence. Road Safety Act 1986 s.57(5).
"1. Driving with a blood alcohol content in excess of .05 grams per 100 millilitres, contrary to s. 49(1)(b) of the Road Safety Act 1986. 2. Having a blood alcohol content in excess of .05 grams per 100 millilitres within three hours after driving, contrary to s. 49(1)(g) of the Road Safety Act 1986. 3. Careless driving, contrary to s. 65 of the Road Safety Act 1986."
He caused to be issued a summons for her attendance to answer these charges at 10.00 am on 21 June 2002 at the Melbourne Magistrates' Court. The informant sought to serve this process on the 2nd and again on 3 June 2002. On each occasion the Ms Platz declined to accept service saying that she would do so only through her solicitors. A remarkable feature of this case is that the informant appears to have accepted this.
"(a) did the learned Magistrate err in determining the charges laid against the Appellant in circumstances where the charge and summons were served less than 14 days before the mention date specified in the summons? (b) was there admissible evidence before the learned Magistrate which entitled him to find that the Appellant's blood alcohol content was in excess of the prescribed concentration of alcohol within 3 hours after driving a motor vehicle in circumstances where the brief of evidence was served less than 10 days before the hearing date".
I am satisfied that the first question should be answered in the affirmative. Section 34(1) prescribes in para (a) the time within which service is to be effected and in para (b) the mode of service. Each commences with the expression "must be served".
"A certificate given under this section must not be tendered in evidence at a trial or hearing referred to in sub-section 2(a), (ab), (b) or (c) without the consent of the accused unless a copy of the certificate is proved to have been personally served on the accused more than 10 days before the day on which the certificate is tendered in evidence".
To my mind, the intent of parliament is clearly expressed. Compliance with the service requirement is a pre-condition to admissibility of a certificate under this section. There is an evident policy underlying this that the defendant should have the opportunity of considering the content of the certificate well before trial. A certificate which has been short-served in terms of the date of its tender into evidence is inadmissible. The second question therefore should also be answered in the affirmative.
[3] Brereton v Sinclair [2000] VSCA 211; (2000) 2 VR 424.
Platz
Barmby [2002] VSC 531
(1993) 19 MVR 55
(2000) 2 VR 424