Xypolitos v The Queen [2014] VSCA 339
[2014] VSCA 339
At a glance
Source factsCourt
Court of Appeal (Vic)
Decision date
2014-12-18
Before
Curtain J, Redlich JA, Tate JA, Priest JA
Source
Original judgment source is linked above.
Judgment (61 paragraphs)
The applicant submits that this direction caused the trial to miscarry, for the following reasons.
72 First, it is argued that the circumstances in which silence in the face of a police investigation can amount to an admission are rare,[31] and that it was not open to the prosecution to invite the jury to treat the applicant's failure to report the killing of the deceased to police as an implied admission. The trial judge, it was said, should not have lent her imprimatur to such a submission. Second, the applicant submits that his silence did not attract the 'doctrine of adoptive admission', as no accusation was made in his presence to which he might reasonably be expected to have responded.[32] Thus it was submitted that it was error to have instructed the jury that it could draw an adverse inference of guilt from the failure to report the death of the deceased. They should have been directed that such evidence bore only upon the credibility of the applicant's account to police and the veracity of his claim that he acted in self-defence, and did not itself constitute evidence of the applicant's guilt.[33]