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[2004] VSC 169
Supreme Court of Victoria
2004-02-18
Redlich J
Original judgment source is linked above.
[2004] VSC 169
Unlawful and dangerous act manslaughter - Objective test as to whether "dangerous act" - Meaning of reasonable person "in the position of the accused" - Emotions of accused - Whether to be attributed to reasonable person.
".......the circumstances must be such that a reasonable man in the accused's position, performing the very act which the accused performed, would have realised that he was exposing another to an appreciable risk of really serious injury."[2]
"The Crown must prove beyond reasonable doubt that the act was dangerous, and what makes an act dangerous for the purposes of manslaughter? The test is this: has the Crown satisfied you beyond reasonable doubt that a reasonable person in the position of the accused - and they are very important words, `in the position of the accused' - that doesn't mean standing somewhere near the vase table, that means in all of the circumstances in which the accused found herself at the moment she threw that vase. A reasonable person in the position of the accused and performing the very same act which Jenny Besim performed would have realised that she was exposing her husband to an appreciable risk of serious injury. That's the test for dangerousness. It's an objective test. That means you don't look into Jenny Besim's mind. You try to assess what would the reasonable person have appreciated at the time that the vase was thrown, but the reasonable person in all the circumstances that Jenny Besim found herself in."[3]
Counsel then submitted that the jury should not be satisfied that it was the accused's intention to hit the deceased on the head with the vase. Counsel went on to say:
"Mr Kayser said to you in his opening that you will have no difficulty in finding that Jenny deliberately aimed at her husband's head. We submit in all the circumstances you would be far from satisfied of it. And if that's right, we submit the question becomes a bit harder for the prosecution. As we see it the question is this on the issue of dangerousness; has the State, the Crown satisfied you beyond reasonable doubt that a reasonable person in Jenny Besim's exact position, that is, if you find these facts, having just been punched, having tired to summons the police, having tried to round-up the kids and get out of there, having almost, if you find it, being simultaneously being the subject of a threat to be burnt with the children in the house, that a reasonable person in that precise position and performing the act of throwing the vase at him would inevitably have realised that she was exposing her husband to the appreciable risk of serious injury. I will say it again because it's complicated. Has the Crown satisfied you beyond reasonable doubt that a reasonable person in Jenny Besim's exact position performing the exact same act would have realised that she was exposing the person at which she was throwing the vase to the appreciable risk of serious injury. That's an element of the offence that you have to be satisfied of beyond reasonable doubt. It's a matter entirely for you. If you form the view that a reasonable person in exactly that position may be so overwhelmed by the circumstances that confronted Jenny Besim, then we would submit that that reasonable person would have had no such realisation that he or she was exposing the other party to serious injury, or if you have a doubt about it, you would acquit on that basis alone. As I say, in my submission you will never get there. This case will stop at the issue of unlawfulness. But if you have to consider whether this act is dangerous, and if you have to apply that objective test to the reasonable person in Jenny Besim's exact position performing the exact same act, then in my submission the Crown have failed to prove that element of the offence as well."[4]
"Where the act which a person is engaged in performing is unlawful, then if at the same time it is a dangerous act, that is, an act which is likely to injure another person, and quite inadvertently the doer of the act causes the death of that other person by that act, then he is guilty of manslaughter."[7] (emphasis mine)
"The correct statement of law is that a man is prima facie guilty of manslaughter if he, without having any intention to kill or do grievous bodily harm, kills another by an act which is both unlawful and dangerous."[9]
"Where an act which a person is engaged in performing is unlawful, then if it is at the same time a dangerous act, that is an act which is likely to injure another person and quite unintentionally he causes the death of that other person by that act, then he has committed the crime of manslaughter."[10]
"An unlawful act causing the death of another cannot, simply because it is an unlawful act, render a manslaughter verdict inevitable. For such a verdict inexorably to follow, the unlawful act must be such as all sober and reasonable people would inevitably recognise must subject the other person to, at least, the risk of some harm resulting therefrom, albeit not serious harm."[12]
"to the type of act from which a charge of manslaughter may result, not the intention (real or assumed) of the prisoner."[14] (emphasis mine).
"The test is still the objective test. In judging whether the act was dangerous the test is not did the accused recognise that it was dangerous, but would all sober and reasonable people recognise its danger."[17] (emphasis mine).
"the risk which, if foreseeable by sober and reasonable people, makes an unlawful act dangerous so that death which is caused thereby is manslaughter. As Staughton J speaking for the Court of Appeal in R v Mitchell[19] said:
`there need not be any intention to injure or kill or any foresight that injury or death would be caused, provided that all sober and reasonable people would have recognised the act to be dangerous'."[20]
Origins of the dangerous act test as formulated by Smith J
".......the accused must be shown to have acted not only in gross breach of a duty of care but recklessly, in the sense that he realised that he was creating an appreciable risk of really serious bodily injury to another or others and that nevertheless he chose to run the risk."[29]
"If ...... a reasonable man could not have contemplated that death or grievous bodily harm was likely to result and death ensued, the proper verdict was said to be manslaughter".[38]
"If a man unintentionally causes death in the course of committing an unlawful act not amounting to a felony, an act such as the accused contemplated or a reasonable man would have contemplated, as likely to create the danger of death or grievous bodily harm ... unintentionally causes death, that is manslaughter."[40] * Subjective test - Longley
"Under the doctrine of manslaughter by unlawful dangerous act the act must be criminal, but it is not necessary that the accused should have realised the risk he was creating."[47]
"......it is sufficient for the present case to say that the circumstances relevant to the question whether a reasonable man would appreciate danger include the physical features of the situation and of the action of the accused man involved. I would not, for my part, include the idiosyncrasies of the accused man or his ephemeral emotional or mental state. They are matters peculiar to him which would affect his judgment of danger but the relevant judgment must be, by definition, the judgment of a reasonable man."[49]
"......one simply looks at what was physically done and decides whether it was likely to produce the appropriate degree of danger. There is, of course, scope for many matters to be included in an observation of what was physically done."[50]
".....I am clearly of opinion that the circumstances of the accused's situation which may be taken into account, whether or not they can include anything personal to him, cannot include anything personal to him which is sought to be included because it may affect his reasoning and his judgment on the question of whether the act is dangerous or not. It may be that facts of the kind sought here to be got in, which are personal to the accused man, might be got in in some circumstances if they were calculated to affect the actual quality of the act itself as dangerous or not when viewed by the reasonable man above, as it were - a question which is wholly unnecessary to decide in this case. (That the firer of the gun knew he suffered from a palsy might provide a case in point). But, like the learned Presiding Judge, I am of the opinion that the scenario, as it were, the state of the stage on which the act is committed which must be considered, cannot include matters which are calculated to influence the judgment of the actor himself as to whether the act was dangerous or not, because that would be to bring into the equation a judgment by a man whose reason and judgment are in a morbid and clouded condition, whereas the reasonable man for the purpose of this particular rule of law is a man who judges with the unclouded reasoning power of a healthy and reasonable mind. I entirely agree with the judgment which has been delivered."[51] (emphasis mine)
"In the end the jury had to determine whether the appellant's act in punching the deceased was, from the stand point of a reasonable person, an act carrying with it an appreciable risk of serious injury to the deceased."[54]
[5] See Russell, William Oldnall (1964) Russell On Crime (10th ed), London, Stevens at 611; Snelling, H.A. 'Manslaughter by Unlawful Act' 30 ALJ 382 and Williams, C.R. `Unlawful Act Manslaughter', [1975] MonashULawRw 4; 1 Mon LR 234.
[12] Footnote 11 R v Church (1965) 2 All ER at 76.
[14] Footnote 13 R v Lipman (1969) 3 All ER at 415.
[15] [1971] VicRp 93; [1971] VR 755 at 758.
[17] Footnote 16 DPP v Newbury at 507.
[19] (1983) 1 QB 741 at 749.
[20] Footnote 18 Boughey v The Queen at 36.
[21] Regina v Lelievre (1962) 32 DLR(2d) 723; R v Adkins Unreported CABC 17 December 1987 and Stuart (1982) Canadian Criminal Law 202.
[30] [1937] UKHL 1; (1937) AC 576 at 583.
[31] [1977] VicRp 50; [1977] VR 430 at 444-445.
[35] Smith, J.C. (1998) Smith and Hogan Criminal law (6th ed.), London, Butterworths at 350.
[37] [1949] VicLawRp 32; [1949] VLR 177 per Lowe, Martin and Barry JJ.
[38] Footnote 36 R v Lumley Headnote at 635 and Footnote 37 R v Brown & Brian at 181.
[40] Footnote 39 R v Parmenter at 314-315.
[41] [1962] VicRp 23; [1962] VR 137 at 141.
[43] Footnote 26 Wilson v The Queen at 341.
[45] Footnote 26 Wilson v The Queen at 333.
[46] Footnote 26 Wilson v The Queen at 328-32; See also R v PDJ [2002] VSCA 211 at [67].
[53] Footnote 26 Wilson v The Queen at 333.
[54] Footnote 26 Wilson v The Queen at 335.
[55] Footnote 27 at 213 per Lush J and at 214 per Fullagar J.
[56] [1971] WAR 110 at 111.
[58] [1990] HCA 61; (1990) 171 CLR 312 at 332; [1990] HCA 61; 50 A Crim R 186 at 197.
[59] Yeo, Professor S., (1997) Fault in Homicide, Leichhardt, NSW, Federation Press at 212.
[60] (1995) 78 A Crim R 504 at 508 per Hunt CJ.
[64] [2002] VSCA 211 at [67] and [74].
[70] (1985) 81 Cr App Rep 150 at 157.
R
Besim [2004] VSC 169
(1986) 161 CLR 10
(1976) 28 FLR 513
(1990) 171 CLR 312
(1996) 68 SASR 17
(1995) 183 CLR 58