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[2015] NSWCCA 114
Court of Criminal Appeal (NSW)
2015-03-11
Meagher JA, Simpson J, Schmidt J
Original judgment source is linked above.
HEADNOTE [This headnote is not to be read as part of the judgment] On the evening of 13 October 2010, CLD (the respondent) and M (the deceased) were present in a shed used for the manufacture of pseudoephedrine when a large explosion occurred. Both were badly burned. M later died as a result of his injuries. The respondent was charged with and pleaded not guilty to a count of manslaughter by an unlawful and dangerous act carrying with it an appreciable risk of serious injury. The Crown argued that the respondent was party to a joint criminal enterprise to manufacture pseudoephedrine in a small, poorly ventilated shed. The unlawful process of extracting pseudoephedrine involved a dangerous act, being the evaporation of toluene, a highly flammable and potentially explosive solvent, in the poorly ventilated space. The evidence at trial established that the explosion could have been ignited by a spark from an electrical appliance or device inside the shed. Other possibilities included a lit cigarette, an ignited blowtorch or a naked flame. The Crown could not and did not seek to identify the ignition source that, in fact, caused the explosion. At the close of the Crown case, the trial judge directed the jury to acquit the respondent, ruling that the evidence could not establish the essential elements of the offence. The Crown appealed against the directed verdict of acquittal under s 107(2) of the Crimes (Appeal and Review) Act 2001 (NSW). The issues to be determined by the Court were: Whether the Crown had to prove the actual source of ignition to make out the elements of the offence; and Whether the Crown had to negate all the possible sources of ignition consistent with innocence because they broke the chain of causation. The court held, allowing the appeal, quashing the verdict of acquittal and ordering a new trial: In relation to (i): It was not necessary that the Crown identify the source of ignition that caused the explosion to establish that the undertaking of the extraction activity in the poorly ventilated shed was dangerous. Whether the activity carried an appreciable risk of injury required a prospective evaluation which took account of all of the possible sources of ignition. It was necessary for the Crown to establish that a reasonable person in the position of the respondent would have realised that multiple potential sources of ignition existed and meant, because of the flammable air mixture and probability of ignition, that the act carried with it an appreciable risk of serious injury: [33], [34], [35]. Burns v The Queen [2012] HCA 35; 246 CLR 334 considered. It was not necessary that the Crown identify the source of ignition that caused the explosion to establish that the respondent's act significantly or substantially contributed to the death of the deceased. It was for the jury to be satisfied that one of the possible sources of ignition raised on the evidence was the actual source of ignition and that the respondent was causally responsible for M's death, irrespective of which of those possible sources operated: [40], [41]. Royall v The Queen [1991] HCA 27; 172 CLR 378 considered. In relation to (ii): Taking the Crown case at its highest, as the trial judge was required to, there was evidence as to there being several possible sources of ignition and it was open to the jury to conclude that one of those possibilities occurred and that the respondent was causally responsible for M's death irrespective of which of those possibilities eventuated: [47].
Judgment
Overview
The evidence as to the source of ignition
The defence submissions in support of a directed verdict of acquittal
The Crown submissions in response
The trial judge's reasons for the directed verdict of acquittal
The Crown's grounds of appeal
Ground 1 (error as to legal requirements necessary to make out elements of offence)
Ground 2 (error as to determination that the Crown had to negate possible causes of ignition consistent with innocence)
Conclusion
Amendments 28 May 2015 - Paragraphs re-numbered from [29] onwards. [43] Correction to last sentence so it reads "It follows" instead of "If follows" DISCLAIMER - Every effort has been made to comply with suppression orders or statutory provisions prohibiting publication that may apply to this judgment or decision. The onus remains on any person using material in the judgment or decision to ensure that the intended use of that material does not breach any such order or provision. Further enquiries may be directed to the Registry of the Court or Tribunal in which it was generated. Decision last updated: 28 May 2015
R
CLD
[1995] HCA 37
[2005] HCA 37
(1989) 18 NSWLR 74
[2010] HCA 17