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[2011] VSCA 306
Court of Appeal (Vic)
2011-10-07
Hansen JA, Weinberg JA
Original judgment source is linked above.
CRIMINAL LAW - Application for leave to appeal against interlocutory decision - Judge ruled evidence of four complainants cross-admissible as tendency and coincidence evidence - No error of principle - Ruling reasonably open - KJM v The Queen (No 2) [2011] VSCA 268 applied - Leave refused.
2 This is an application for leave to appeal against an interlocutory decision of a judge in the County Court that tendency and coincidence evidence is admissible on all charges in Indictment Y02852643. I mention the number of the indictment as in the same ruling the judge dealt with a separate indictment, Y02852643.1, involving other complainants in which she held that tendency and coincidence evidence is not admissible. The Crown not having sought to appeal from that ruling, no question arises on this application as to the correctness or otherwise of the ruling on that second indictment.
3 The subject indictment with which the present application is concerned contains 25 charges concerning four complainants. Except for one count of a threat to kill, all charges are sexual offences and some offences of violence committed against four female family members between 1970 and 1992. The complainants are respectively a sister, two nieces and a daughter of the applicant. The effect of the ruling is that their evidence is crossadmissible at the trial.
4 The evidence proposed to be led is of charged and uncharged acts specified in separate tendency and coincidence notices.
5 The judge records in her ruling that there was no real argument that the evidence was relevant to the fact in issue. That was not surprising, given that the applicant denies that the offending occurred.
6 In her ruling the judge gave careful consideration to the submissions of counsel, noting that there were no differences between them as to the relevant principles, and analysed the proposed evidence and the issues that arose respectively under ss 97, 98 and 101 of the Evidence Act 2008. In accordance with the request of the County Court the ruling is attached to these reasons.
7 The applicant contends that the judge erred in ruling that the tendency and coincidence evidence is admissible. That was said to be constituted by the following erroneous findings:
(a) that the similarities relied upon by the prosecution had significant probative value;
(b) that the evidence of each complainant could be used by a jury to discern a pattern of behaviour; and
(c) that the similarities relied upon were sufficient to make it improbable that the behaviour described by each complainant occurred coincidentally.
8 In developing these basic contentions counsel for the applicant pointed to aspects of the various acts of offending in order to draw distinctions and dissimilarities as to the time, location, and the nature of the allegations to establish that neither alone nor in combination could they constitute tendency or coincidence evidence. He submitted that no judge acting reasonably could have concluded as her Honour did.
10 In my view it was reasonably open to the judge to conclude as she did. There is no error of principle and it is not suggested that she did not take into account the relevant facts and circumstances. Rather, the challenge is made as to her evaluation of those matters.
11 The applicant raised one further point that was not raised before the judge. That was that concoction or contamination may be considered when considering the
probative value of the evidence. Doubtless in principle that is so, but there must be a basis for doing so as distinct from mere speculative suggestion. If it is desired to raise the point it should be done before the judge. To seek to raise the point before this court now for the first time is to short-circuit the ordinary processes. It is apparent from what counsel said that it is a point that he desires to raise and accordingly it should be left to be considered by the trial judge. In that sense the present application may be seen to be somewhat premature.
12 Somewhat similarly, in the course of his submissions counsel for the Crown raised the possibility that the trial might be more conveniently conducted if the Crown elected to rely on one only of the tendency or coincidence evidence. That, of course, is a matter for the Crown to decide in the conduct of the case.
13 For these reasons in my view the application should be refused.
16 The order of the court is that leave to appeal will be refused.
To qualify as a relevant similarity in circumstances such as these, there must be something distinctive about the way in which the accused allegedly took advantage of the setting or context. In the present case, senior counsel for the Crown did not seek to identify any such distinctive behaviour and we were not persuaded that there was any.
Those matters are all aspects of the setting in which the offending occurred and of the pre-existing relationship between the alleged offender and the victims. It is plain enough that on the allegations it was that setting and that relationship and the fact that the children were left alone with the accused which provided the opportunity for the alleged offending to have occurred.
If that were all that could be said in support of the coincidence notice, the notice would, in my opinion, be unsustainable for the reasons set out in paragraphs 19 and 20 of PNJ, but this case is quite different from PNJ because of the way in which the applicant took advantage of a situation which, I am assuming for present purposes, he did not create.
[1] [2011] VSCA 268, [12].
S P A
The Queen [2011] VSCA 306
(1936) 55 CLR 499