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[2003] VSCA 76
Court of Appeal (Vic)
2003-06-19
CHARLES, BUCHANAN and VINCENT, JJ.A.
Original judgment source is linked above.
"1. The trial judge erred in his directions concerning the elements of negligence in each count; and in particular - (a) he failed to direct sufficiently or at all that the negligence required was the same as for the crime of manslaughter; (b) he failed to direct sufficiently or at all that, in order to convict, the jury were required to find such a great falling short of the standard of care which a reasonable person would have exercised in the circumstances, and which involved such a high risk that death or grievous harm would follow, that the driving causing death merited criminal punishment. 2. The trial judge erred in that his directions were apt to withdraw the element of causation from the jury. 3A. A miscarriage of justice resulted from the taking of majority verdicts before the jury had deliberated for at least six hours. 3B A miscarriage of justice resulted from failure of the trial judge to give further directions, before accepting majority verdicts, to the effect that - (a) it was still preferable that the jury endeavour to reach unanimous verdicts; (b) the jury should endeavour to do so unless it was hopeless."
"We are here concerned with a criminal trial. With the criminal law and in this case, as each counsel has put it to you, the Crown must prove that the accused failed, unjustifiably and to a gross degree, to observe the standard of care which a reasonable person would have observed in all the circumstances of the case. To prove the forbidden act of driving in this case, the Crown must prove not merely that the accused failed to exercise reasonable care for the safety of others, which would be the case in a civil trial for damages, but this departure from that standard of care owed to others, was such that it deserved to be called a gross departure from that standard. The Crown must prove beyond reasonable doubt that the accused was, to a gross extent, negligent."
Thereafter his Honour reiterated on several occasions that the Crown was obliged to prove that the accused was negligent to a gross extent.
"[T]he proper course for the trial judge to adopt is to confine himself to the very terms of the relevant legislation to draw attention to the requirement that the jury must be satisfied that there has been a failure on the part of the accused to observe the prescribed standard of care and that the failure must not only be unjustified but must be to a gross degree. The legislature has in words prescribed the degree of departure from the standard of care required to constitute the offence, and to do more than emphasize that the departure from the stated standard of care must be gross is only likely to obscure the nature of the task before the jury."[5]
"It is sufficient if bad driving was a substantial and operative cause of the death. It does not have to be the sole cause of it. Obviously a mistake made by another driver, or some other circumstance or circumstances, might be a part of the totality of the things which lead to the occurrence of the death, but if one of the substantial and operative things causing the death was the forbidding driving, then in law, the death has been caused by it."
That statement was unexceptionable. Unfortunately, his Honour went on to say in effect that causation was not in issue. He told the jury:
"Now it is very important that you realize that that is not the end of it. The fact that the death was caused by the accident. No one argues about that and no one argues that the driving of the accused man was a substantial and operative cause of the death. The battleground is in this particular forbidden way of driving."
The trial judge's subsequent remarks reinforced the impression that the only issue was whether the applicant's driving was negligent to a gross degree. He said:
"I repeat, the Crown must prove that in driving his motor vehicle, the accused departed to a gross degree, from the standard of care he owed to others in all the circumstances of the case, that the death of another person occurred, that is not in issue, and that the accused's departure from the standard of care he owed to others, was a substantial and operative cause of that death. Now, I repeat, the battleground in this case is this area of failing unjustifiably and to a gross degree to observe the standard of care which a reasonable person would have observed in all the circumstances of the case."
"So far as the addresses of counsel are concerned, Mr Gibson said in his opening that you should rely on your common sense and that the driving of the deceased was a substantial and operative cause of the death, and that is not in issue."
"You can talk about it over lunch, but no one expects you to be deliberating over lunch hour."
and causation were deficient, I would grant leave to appeal against the conviction, treat the appeal as instituted and heard instanter, allow the appeal and order a re-trial.
[2] [2003] VSCA 55 at para.[19].
[4] [2002] VSCA 158 at [46].
[5] R. v. Horvath [1972] VicRp 60; [1972] V.R. 533 at 539 per Winneke, C.J., Little and Stephen, JJ. See also R. v. Lucas [1973] VicRp 68; [1973] V.R. 693 at 701 per Newton, J. and Norris, A.J.; R. v. Stephenson [1976] VicRp 34; [1976] V.R. 376 at 382-3 per Young, C.J., Nelson and Harris, JJ.
[7] At [2] per Ormiston, J.A. and at [46] per Charles, J.A.
[9] R. v. Herring (1994) 74 A.Crim.R. 72. Cf. R. v. Savvas (1991) 55 A.Crim.R. 241.
[10] See R. v. Dalloway (1847) 2 Cox C.C. 273. Cf. R. v. Marsh [1997] Crim.L.R. 205.
[11] R. v. Rudebeck [1999] VSCA 155 at [66] per Ormiston, J.A.
R
Heron [2003] VSCA 76
Criminal law - Culpable driving - Charge to jury given before decision in R. v. De'Zilwa [2002] VSCA 158 - Explanation of gross negligence required in the circumstances of the case - Causation - Issue whether the culpable element in the driving caused death wrongly taken away from jury.