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[2001] VSCA 198
Court of Appeal (Vic)
2001-10-31
WINNEKE, P., BROOKING, J.A. and O'BRYAN, A.J.A.
Original judgment source is linked above.
[ 2001] VSCA 198
Criminal law - Conviction and sentence - Rape - Whether acts of physical assault preceding rape admissible - Whether judge erring in failing to discharge jury when evidence of uncharged acts inadvertently elicited in cross-examination - Judge's directions in relation to evidence of physical assaults adequate in circumstances of case - Significance of failure to take exception - Circumstances in which Court will receive evidence of events occurring subsequent to sentence discussed - Applications dismissed.
"Q: You have told the jury that you had concerns about the fact that he was still the father of your child?
Q: That you thought maybe he could get some help and this situation might get worked out in some way?
A: Yes. Q: And that it might not happen again? A: Yes. Q: That's why you didn't want the police involved and you didn't want him arrested? A: That's right. Q: But you do say that the straw that broke the camel's back on that night is when you say that he raped you. As a result of that you did go and see the police? A: Yes. Q: You did contact the police? A: I did. Q: You'd made up your mind at that stage that one way or the other this man was going to be out of your life. Isn't that right? A: He has been mentally and physically abusive but it was never as bad as this incident. ... Q: You wanted him out of your life? You wanted him arrested? Isn't that right? Isn't that why you called the police? A: I wanted to take him out of the house. I ... didn't want him to be out of my life but he made me call the police because of what he's done to me in the bedroom. ... Q: Because of that? A: Because he never betrayed me in that way. He may have assaulted me but he never betrayed me in that way and I felt - that scared me."
At another point during the cross-examination the following questions were asked and answers given:
"Q: Do you say that you did suffer injury to your lips or you didn't? A: I'm sorry but I'm not sure because this kind of abuse, not as bad but it had happened. Q: I'm not asking you about other occasions which may or may not have happened, I'm asking you about ... this occasion? A: I don't understand. Q: When you say you're not, whether or not you suffered injury to your lips although you do recall saying that that had happened on a previous occasion? A: Yes I do, but I'm not too sure."
"... I would ask Your Honour to consider a discharge of this jury. The alternative to that, and it's not a very good alternative, is that they be directed in some way as to how they are to approach not only that evidence that's come out in the box, but also the matters which have been led by the Crown leading up to the allegation they're being asked to determine."
" ... I have no hesitation in saying that I do not believe there is sufficient to discharge the jury on the answers that have fallen from the witness in this matter. It is a matter that can be dealt with again when the jury are being charged by me that the assaults, particularly of the night, and they are the only ones I'll be specifically referring to in the charge, with perhaps a sentence on any other matter of a similar kind is simply in context. ... Similar type responses were I suggest innocently given by (the complainant). I don't think that she is of the intellect to understand the system to be deliberately trying to ... I suppose one, when questioning (the complainant) could couch the question in such a way as to try and avoid that sort of response but I certainly do not believe it is proper that I discharge the jury for the responses she has given at this time."
"2. That the learned judge erred in that he allowed evidence to be led as part of the Crown case that the facts and circumstances alleged to constitute the offence of causing serious injury (the charged act) to which I had pleaded guilty, but evidence of which plea was not led before the jury. 3. That the learned judge erred in that he refused to direct the jury at the time that the evidence was led in relation to the charged act as to the permissible use they might make of that evidence. 4. That the learned judge erred in refusing an application to discharge the jury made as a consequence of uncharged acts not relied upon by the Crown being introduced into evidence during cross-examination. 5. That the learned judge erred in that he did not adequately or at all address the jury in the course of his charge as to the permissible or impermissible use they might make of the evidence in relation to the charged act and the uncharged acts and in particular he erred:
(a) in referring to 'what (the complainant) says of (the applicant) in terms of his mood swing, his fluctuations of mood, his inconsistency when he is intoxicated and being assaulted';
(b) in failing to direct to the effect that the evidence of previous and subsequent acts of violence must be disregarded;
(c) in failing to direct to the effect that the jury:
(i) must not substitute evidence of physical assault on the night with evidence of the sexual assault; and (ii) must not reason that because the applicant had physically assaulted the complainant earlier that night he was the kind of person likely to have sexually assaulted her."
Failure to Exclude the Evidence of Physical Assaults - Ground 2
"I do not accept that non-specific highly prejudicial evidence may be led by the prosecution, and juries told that it might provide 'part of the essential background' against which the other evidence is to be evaluated."
Failure to Discharge the Jury Following Evidence of History of Violence - Ground 4
Grounds 3 and 5 - Directions in Relation to Physical Assaults
"Let me say as well you might recall ... [the complainant] gave evidence of an assault. The assault that occurred, I will call it if you like, the first event, is led in evidence as being in context of what happened on that night. That that event occurred does not mean to say that the rape event occurred, the second event. It would have been a nonsense for you not to have heard what occurred on the night and there is, as you heard, and conceded by counsel, no dispute about the unpleasantness of the first event. In fact, the first event came to a conclusion, there was a break ... . That event was finished and completed, that's the first event and then the second event occurred. The fact that the first event occurred is not an element of the charge of rape. But so that you are aware of the entire events of the evening and the state of mind of the victim and what she says of the accused in terms of his mood swing, his fluctuations of mood, his inconsistency when he is intoxicated and being assaulted (sic). That is a separate event and not to be treated as the rape event. I've said that two or three times."
These directions were almost identical to directions which the judge had given to the jury in the first trial, which of course involved the same counsel. No exception was taken by the applicant's trial counsel to the directions given in that form. Although no specific direction was given in respect of the evidence of physical acts of violence committed by the applicant on "other occasions" (if that is what it was), no direction was sought and no exception taken to the charge on that point. Perhaps that is understandable because, having regard to the vagueness of such evidence, it might well have been considered imprudent to have emphasised the brief references to such acts.
sentences imposed are otherwise than adequate for the crimes committed, and accordingly I would reject the application for leave to appeal against sentence.
[3] (1970) 123 C.L.R.334 at 339 per Barwick, C.J.; 334 per Menzies, J.
[5] (1989) 168 C.L.R.266 at 279 per Toohey, J.
[6] Unreported, Court of Criminal Appeal (N.S.W.) 31 August 1995 per Gleeson, C.J. at 7-10.
[11] [2000] 1 V.R.235 at [7]-[8] and [15].
[12] Unreported, Court of Appeal (Vic.) 27 November 1997 at pp.8-9 and 13-15.
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