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[1999] VSC 420
Supreme Court of Victoria
1999-10-26
TEAGUE, J.
Original judgment source is linked above.
* the physical mental and emotional state of the accused;
* the location where the conversation was held, and more specifically whether the accused was in detention;
* the status of the person with whom the conversation was held, and the relationship of that person to the accused;
* the existence and if so the character and level of any improper conduct on the part of police;
* the manner in which information was volunteered as against being actively elicited;
* whether the accused had earlier exercised his right to remain silent; and
* the assessment it is possible to make of the reliability of what was said by the accused.
* the level of potential ambiguity in what is said;
* the relevance of what is said to issues in the trial;
* the character of the exchange, and whether a response is volunteered or actively elicited (as to which see Swaffield and Pavic, and my ruling in Lewis)
* whether the response comes in answer to the putting of an open question or a closed question or the stating of an opinion or an expression of emotion or some other position;
* whether there is a positive response to a question;
* whether there is not one but two or more propositions in a question or statement potentially calling for a response;
* whether there is some other potential for prejudice, such as that there is in a question or statement an accusation of an uncharged criminal act.
R
Nguyen [1999] VSC 420
(1998) 192 CLR 159