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Evidence Tom Spohr Evidence Tom Spohr

Wright v R [2025] NSWCCA 108

The Court of Criminal Appeal (‘CCA’) has held that a tendency notice served only a few days before trial can still amount to ‘reasonable notice’ under the Evidence Act, provided it causes no actual prejudice to the accused, and despite requirements for it to be served typically many months earlier.

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Evidence Tom Spohr Evidence Tom Spohr

R v Walker [2025] NSWCCA 62

In this decision about a jury direction, the Court of Criminal Appeal (‘CCA’) has commented on the emerging view that in-person evidence has advantages over video evidence. The obiter comments are likely to be worthwhile reading for any practitioner making or opposing an application that a witness g

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Evidence Tom Spohr Evidence Tom Spohr

Wild v Meduri [2024] NSWCA 230

This is a rare civil case which has important consequences for criminal lawyers. In the shadow of a debate which has been playing out over whether conversations in affidavits need to be in the first person or not – ideally they should, but it depends on the witness’ memory – the NSW Court of Appeal

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Evidence Tom Spohr Evidence Tom Spohr

Gardiner v R [2023] NSWCCA 89

In this decision the Court of Criminal Appeal (‘CCA’) has determined that although judges in judge-alone trials are entitled to take into account the demeanour of witnesses outside the witness box (for example in the dock, or in the well of the Court), the judge should immediately bring to the atten

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Evidence Tom Spohr Evidence Tom Spohr

Barney v R [2023] NSWCCA 85

In the course of considering this appeal, the Court of Criminal Appeal has discussed the concepts of ‘credibility’ and ‘reliability’ in a way that is likely to be useful for practitioners appearing in hearings and appeals at all levels.

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Evidence Tom Spohr Evidence Tom Spohr

Kanbut v R [2022] NSWCCA 259

In this decision the CCA has observed that a tendency notice which simply asserts all the allegations in the prosecution case is unlikely to meet the objectives of the tendency rule, and examined the injustice which can arise when the jury directions from such a faulty tendency notice do not correct

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Evidence Tom Spohr Evidence Tom Spohr

R v Russell [2022] NSWCCA 294

In this decision the Court of Criminal Appeal (‘CCA’) has examined whether a witness who is unresponsive or silent will give rise to exceptions in the Evidence Act which would otherwise allow the tender of an earlier statement, either based on the credibility rule, or based on the ‘maker unavailable

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Evidence Tom Spohr Evidence Tom Spohr

Ahmed v R [2021] NSWCCA 280

In this decision the Court of Criminal Appeal has held that in cases where the accused bears an onus in relation to a defence, there is a particular need for the judicial officer to direct themselves that the failure of the accused to give of sworn evidence cannot be used as a factor on the question

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Evidence Tom Spohr Evidence Tom Spohr

R v Riley [2020] NSWCCA 283

In this decision the Court of Criminal Appeal (‘CCA’) has considered a case where illegally-obtained evidence was rejected by a trial judge. In making the determination, they held that the probative value of the evidence must be taken at its highest, excluding (in all but the most extreme circumstan

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Evidence Tom Spohr Evidence Tom Spohr

SB v R [2020] NSWCCA 207

In this decision the Court of Criminal Appeal (‘CCA’) has held that evidence of complaint is not ‘independent’ of the complainant. To the extent that the Criminal Trials Bench Book had a recommended direction to that effect, it was wrong.

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Evidence Tom Spohr Evidence Tom Spohr

Higgins v R [2020] NSWCCA 149

This decision reinforces previous authority in relation to the co-conspirators rule, and particularly the (in)admissibility of certain kinds of admissions made. It also draws specific attention to the test for the taking of ‘judicial notice’ of things, and emphasises the importance of the court givi

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Evidence Tom Spohr Evidence Tom Spohr

Jurd v R [2020] NSWCCA 91

The Court of Criminal Appeal (‘CCA’) has determined where spouses and other family members have a right to object to giving evidence for the prosecution, the procedure needs to be followed carefully – especially since (contrary to some older authority) it has the capacity to affect the rights of the

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Evidence Tom Spohr Evidence Tom Spohr

Jackson v R [2020] NSWCCA 5

The Court of Criminal Appeal (‘CCA’) has considered whether, in light of recent High Court authority, there is a different standard of proof to be applied to uncharged acts when there is only one complainant in sex matters, versus when there is more than one. This was not thought to be the right veh

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Evidence Tom Spohr Evidence Tom Spohr

Vasilevski v R [2019] NSWCCA 277

What is the truth, anyway? In a debate befitting the times of ‘alternative facts’, the CCA has considered whether offences of persuading someone to withhold ‘true evidence’ refer to evidence that the witness believes to be true, or evidence which is objectively true. Although strictly unnecessary to

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Evidence Tom Spohr Evidence Tom Spohr

Hogg v R [2019] NSWCCA 323

In this decision of the Court of Criminal Appeal (‘CCA’), the Court has examined the use of the ‘special caution’ and how it may (or may not) qualify the right to silence.

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Evidence Tom Spohr Evidence Tom Spohr

AB (a pseudonym) v R [2019] NSWCCA 62

In a decision with consequences for retrials where the complainant’s evidence was recorded (and which might be relevant in other matters where some of the evidence is pre-recorded), the Court of Criminal Appeal (‘CCA’) has determined that it will seldom, if ever, be appropriate for the recording to

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Evidence Tom Spohr Evidence Tom Spohr

Bandao v R; Bruce v R [2018] NSWCCA 181

In an era where everybody has a mobile recording device immediately to hand, what happens if material comes to light which might be relevant to a defence, but might also have been recorded illegally? In this decision of the Court of Criminal Appeal, the court has set out a step-by-step process which

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Evidence Tom Spohr Evidence Tom Spohr

Odisho v R [2018] NSWCCA 19

The Court of Criminal Appeal (‘CCA’) has examined applications for leave to cross examine one’s own witnesses under s38. The core principle seems to be that grants of leave will be strictly interpreted, and if there is any possibility that cross examination will stray into territory which is only ab

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KN v R [2017] NSWCCA 249

The CCA has determined that it is within a trial judge’s discretion to order that audio visual link (‘AVL’) evidence can be given from the complainant’s home, using their own computer and software.

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