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[2004] VSC 110
Supreme Court of Victoria
2004-04-02
Nettle J
Original judgment source is linked above.
[2004] VSC 110
CRIMINAL LAW - practice and procedure - severance - application for separate trial - test to be applied.
s first, that where two or more persons are charged with murder at which all were present at the time of the killing, the interests of justice ordinarily require that they be tried together;
s secondly, the fact that one accused alleges that he was coerced or otherwise influenced by the other will generally be a reason for adhering to a joint trial;
s thirdly, while the Crown may be inhibited to some extent in the evidence that it may adduce at a joint trial, an accused should be allowed to lead in his defence, whether by calling witnesses or cross-examination, any evidence which is relevant to his defence;
s fourthly, while the court retains an exercise to exclude such evidence, the occasions for exercise of the discretion will be rare and it is not to be exercised simply because one accused wishes to elicit evidence of bad character of another accused;
s fifthly, care must be taken to explain to the jury that the case against each accused must be considered separately; and
s sixthly, there are some cases in which such a direction will be ineffective and they may occur where one or at least perhaps more than one of the following considerations apply: where out-of-court statements of co-accused contain grave allegations of bad character of the accused; where there is evidence irrelevant to any issue between the Crown and the accused and which could not have been led at a separate trial of the accused but is admissible as to an issue between the Crown and the co-accused and is highly prejudicial to the accused; where evidence irrelevant to any issue between the Crown and the accused is admissible against a co-accused, and as against the co-accused serves to corroborate or reinforce the evidence of an eyewitness against the co-accused, and as a result the jury would be likely to believe the eyewitness, not only in what he or she may say against the co-accused, but also in what he or she may say as against the accused, at least where the Crown places heavy reliance upon that witness to implicate the accused and the evidence is open to serious challenge.
"In such case there would be no doubt or confusion in the jury's mind about the inadmissibility of statements made by [one accused] in the case against the [other accused]."
[5] [2000] SASC 454 at para. 91, reviewed on appeal on other grounds, at 78 ALJR 64; [2003] HCA 64
[24] (1986) 8 NSWLR 12 at 16-17
[25] (1983) 8 A Crim R 437 esp at 449
R
Iaria and Panozzo [2004] VSC 110
(1982) 148 CLR 668
(1986) 8 NSWLR 12