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At the first meeting of our new Council a new committee structure was established.

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CHAIRS ON STANDING COMMITTEES

Family Law Committee - Rebecca Curran
Civil Law Committee - Andrew Berger
Rule of Law Committee - Philip Walker SC
Criminal Law Committee - James Lawton
Events Committee - John Masters
CPD Committee - Alicia Irving

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Ken Archer
President

The High Court (French CJ Bell Gageler Keane and Gordon JJ) handed down a judgment concerning hearsay evidence and inconsistent verdicts that will be referred to in appeal courts all over Australia.  Sio drove F to a brothel.  F entered the brothel alone armed with a knife intending to commit robbery.  F stabbed G, a brothel worker, who died. F removed G’s pencil case which contained cash and left the brothel running past Sio’s car.  Sio collected F and accelerated away from the scene.  Sio was charged with the murder of G and also armed robbery with wounding.  Sio was acquitted of murder but convicted of armed robbery with wounding.  The NSWCCA dismissed Sio's appeal who then sought special leave which was referred to the Full Court of the High Court. 

The issue of inconsistent verdicts and F’s representation in police statements, that Sio gave him (F) the knife, arose for determination.  At the trial F refused to answer any questions and the statements were tendered over objection that the statements were hearsay relying on s 65 of the Evidence Act, which states that the hearsay rule does not apply to evidence of a previous representation that is given by a person who saw, heard or otherwise perceived the representation.  If the representation was against the interests of the person who made it at the time, it was made and was made in circumstances that make it likely that the representation is reliable.
 
In relation to the unreasonable verdict issue the Court referred to Gilbert’s case wherein Gleeson CJ and Gummow J said:
“The system of criminal justice, as administered by appellate courts, requires the assumption that as a general rule, juries understand and follow the directions they are given by trial judge”.
 
The Court referred to the serious consequences of the successful invocation of s65 (2)(d) which emphasised the need for compliance with the conditions of admissibility prescribed in the section which has the associated benefit of being conducive to the preservation of clarity, good order and fairness in the conduct of criminal trials.
 
Wigmore’s comments about the circumstances of the hearsay utterance being made such that a sincere and accurate statement would naturally be uttered and no plan of falsification be formed, i.e. in circumstance that tend to negative motive and opportunity of the declarant to lie.  Evidence by an accomplice against a co-offender has long been recognised as less than inherently reliable and thus the Court held it was in these circumstances not open to the trial judge to be satisfied positively of the likely reliability of F’s assertion that Sio gave him the knife and ruled that the evidence should not have been admitted.

Chief Justice Warren recently gave a paper at the London 2016 International Commercial Law Conference. The Chief Justice pointed out that in Victoria there is a specialists Costs Court, judge and registrar together with recent legislation which imposes an obligation on practitioners to ensure costs are reasonable and proportionate before moving onto her important comments on the contribution made by the Commercial Bar in contradistinction to the Criminal and Common Law Bars. The Chief Justice boldly stated that “we are able to live and function in an orderly society because of the work commercial barristers do.  Unlike, she says, that in Russia where the lawyer Sergei Magnitsky found that after he complained about corruption in Russian companies he was arrested and detained for a year; or in the Philippines wherein the new President Duterte has directed the citizens to take the law into their own hands and kill wrongdoers themselves. 

The Commercial Bar in Australia plays an important part in the governing of commercial behaviour because the corporate world seeks advice from the Commercial Bar as to the limits of what may be done which can then be adjudicated on by the courts.  ASIC and APRA also play an important role in maintaining conduct and corporate behaviour". The Chief Justice referred to the Australian Wheat Board case as an example of ASIC’s involvement in fashioning corporate behaviour and to Heydon J’s comments in AON v ANU about “commercial life”. The Chief Justice observed that commercial litigation and specifically mega litigation can be of vital value in delivering justice for the community.

Farewell to Svetlana Todoroski

Svetlana has been the longest serving Chief Executive Officer of the ACT Bar Association, holding that position for over 14 years from February 2002 until August 2016 – working with nine presidents and the editor of the Bar Bulletin.

Svetlana was intimately involved when the ACT Bar Association went from a largely voluntary association to a statutory regulatory body in the ACT. She was also involved in introducing BarCare for members, a confidential counselling service, as well as developing the Continuing Professional Development Program in the ACT. 

Svetlana has been a champion in promoting women at the Bar and was instrumental in gaining sponsorship to establish scholarship incentives for women and Readers practising at the private referral Bar. She was also regularly involved at multi-level discussions with various stakeholders, including Government entities.  Svetlana graduated from the University of Canberra in 2015 with a master’s degree in Juris Doctor and after completing her graduate diploma in Legal Practice at the ANU she was admitted as a legal practitioner of the Supreme Court of the ACT on 11 December 2015.  Svetlana’s resignation as the CEO resulted from her accepting a position as a solicitor in a local firm.  Svetlana has of course been involved in the production and distribution of the Bar Bulletin. She has organised the printing, layout and photographs, as well as obtaining advertising support.  Svetlana has been involved in securing many of the contributions that appeared in the Bulletin.  She has reminded, cajoled and nagged the regular contributors to have this contribution ready for the incoming edition.  Svetlana has made an enormous contribution to the corpus of the Bar and her organisational skills will be sorely missed.  I will certainly miss her and thank her most sincerely for her past hard work. I wish her well in the new challenge in private practice.​​
 

Legal Aid Commission Update

President Jon Stanhope

In the past year the Commission has, as expected, been required to manage its resources in a turbulent environment. I am pleased to be able to report that, notwithstanding these demands, services to the Canberra community have not only be maintain but expanded. Like all other legal aid commissions around Australia we have an important remit – to help the most vulnerable and disadvantaged people in our society, and here in the ACT I am very pleased the Commission is rising to this challenge.

There are very good reasons why legal aid commissions play an integral role in our legal system. Chiefly, of course, they are charged with providing equal access to legal remedies for those persons who would suffer most without this assistance. If we are to make our community an inclusive society, then access to legal assistance is an imperative bottom line.  Many years ago this challenge was laid down by Lionel Murphy, then the Attorney-General of Australia, when he caused the Australian Legal Aid Office to be established (ALAO).  In his Ministerial Statement he said:

“The Government has taken action because it believes that one of the basic causes of inequality of citizens before the law is the absence of adequate and comprehensive legal aid arrangements throughout Australia….the ultimate objective of the Government is that legal aid be readily available to citizens…and that aid be extended for advice and assistance of litigation as well as for litigation in all legal categories and in all courts.”

The ALAO was the forerunner of all legal aid commissions around Australia, and the charter Lionel Murphy set out is as true today as it was then. Importantly, he thought that ready accessibility to legal assistance was crucial, and considered that ‘storefront’ legal aid offices were key to the successful delivery of services. I am very pleased to see that our Commission has taken up this approach – by providing a new ‘storefront’ service, and by running 12 legal advice clinics in suburbs all around Canberra; by taking over 16,000 calls on the Helpline, and by investing in social media. 

 While it is sadly true that there can never be enough money to close the ‘justice gap’, it is equally true that legal aid commissions must try to optimise the number of people who are able to receive assistance. The marked increase in grants of legal assistance this year also ably demonstrate how the Commission is trying to meet this challenge.

The Commission is an independent statutory authority within the ACT. This is clearly set out in the legislative framework that underpins the daily operations of the Commission. Primarily, and this is in the interest of both government and citizens, the Commission must provide frank and fearless legal representation to its clients – this is fundamental and necessary. And while the Commission has a responsibility to undertake its activities as an integral part of the Commonwealth and Territories Government justice polices under the National Partnership Agreement, the independence of the Commission, including financial independence, should not be compromised. Appropriately,
 
Accountability indicators, audit requirements and the financial management legislation, govern the operations of the Commission, and in that sense the Commission’s management decision should not be undercut unnecessarily by bureaucratic or political intervention.  New challenges, not least the perennial concern about limited funding, and the need to be adaptable and flexible in service delivery, will no doubt drive the work of the Commission over the coming year. 
 
Jon Stanhope
President

The Bench and Bar Dinner held at the Boat House on Friday 2 September was a wonderful success and enjoyed by members.  We thank Patrick O'Sullivan, President of the ABA who toasted the Bar on the evening and  special guest speaker, The Hon Chief Justice Tom Bathurst AC.  We also thank Mr Stuart Carter from MLIG for generously sponsoring the wine on the night.  Thank you also to Mr Michael Miller of MLC Advice, who also attended, and who again sponsored the ACT Bar Women's Scholarship.

The ACT Bar Association's Women's Scholarship
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Overview of section 44 Bail Act
Section 44 gives the DPP, in matters involving a domestic violence offence or a serious offence, a right to apply to the Supreme Court for a review of the decision by a Court granting an accused person bail.

An application for review can be made when the DPP considers exceptional circumstances exist and it is in the public interest to make the application (section 44(2)).

There are a number of legislative requirements relating to the application for review contained in section 44. The prosecutor must give oral notice of the intention to apply for review to the Court granting bail at the time the original bail decision is made (section 44(4)). A formal application to the Supreme Court must be made by the DPP within 2 hours of the original bail decision being made and written notice of such must be given to the accused person within this time (section 44(3)).
Section 44(5) places legislative limits upon the stay of the bail decision. The accused person can only be detained until the first of the following occur:
                  (a) the DPP tells the Court that granted bail that the application will not proceed;
                  (b) 2 hours has passed and the DPP has not;
                       (i) made an application, and
                       (II) given written notice to the accused person;
                  (c) the Supreme Court makes a decision on the application;
                  (d) 48 hours has passed since oral notice was given to the granting Court and the Supreme Court has not made a decision on the application.

Application of section 44 Bail Act             
Section 44(7) provides which types of offence the application for review can apply to.  These include domestic violence offences and serious offences.

For the purposes of section 44(7), the definition of domestic violence offences in section 13(2) Domestic Violence and Protection Orders Act 2008 applies. There are 61 such domestic violence offences.  Serious offences as defined in section 44(7)(a-d) Bail Act include at least 28 offences.

This figure does not include those that fall within s44(7)(a), which refers to an offence of causing harm, or threatening to cause harm with a maximum penalty over 10 years. ‘Causing harm’ is not defined in the Bail Act and no indication is given whether the definition of harm in the Criminal Code (2002) ACT, which includes mental harm, is to be applied. If that definition is to be applied, it will increase again the number of offences the definition of serious offence applies to.
 
Exceptional Circumstances
The language in section 44(2) Bail Act requires the DPP to consider that exceptional circumstances exist and it is in the public interest to make the application for review. The section does not provide whether the prosecution needs to establish, as a threshold question, that exceptional circumstances exist, before the review is carried out.  A question in the operation of the section then arises, does the Supreme Court need to be satisfied by the prosecution that exceptional circumstances exist before they proceed to conduct a review?

A literal reading of the section does not appear to require it, but such a threshold question should, in fairness, be necessary. It is not readily conceivable that the Supreme Court would conduct a review of a decision to grant bail, made in line with legislative requirements of the Bail Act and judicially determined, because the DPP alone believes there are exceptional circumstances warranting a review. 
Exceptional circumstances are not defined in the Bail Act, but the phrase ‘special and exceptional circumstances’ has been considered by the Courts in other contexts, and generally found to mean circumstances that are unusual or uncommon.
If exceptional circumstances need to be established in an application under section 44, it would be for the prosecution to establish unusual or uncommon circumstances exist that warrant a review of the decision to grant bail. The onus would lie on the prosecution and it would need to be established on the balance of probabilities (section 55 Bail Act).

Human Rights Act issues
In interpreting and applying section 44 Bail Act, Human Rights Act 2004 (ACT) considerations could come into play.
Of note, section 18 Human Rights Act provides the right to liberty and security of person.  Questions may arise as to whether the detaining of an accused in circumstances where oral notice is given but no formal application is subsequently made is arbitrary detention.

Further, the existence of the Human Rights Act lends weight to the argument that the threshold question of whether exceptional circumstances exist must be established by the prosecution before the Supreme Court will undertake a review of the original decision granting bail. 

In the matter of an application for bail by Luke Marsh [2013] ACTSC 16 [at para 28] it was noted but not positively determined that the Human Rights Act may require the interpretation of ‘special and exceptions circumstances’ to be determined in a Human Rights compliant manner. This could equally apply to section 44 Bail Act applications for review.
 
Conclusion
Section 44 Bail Act has potential application to a large number of offences. The provision gives the DPP a power not previously enjoyed.  When it commences operation on 1 May 2017, it will be interesting to observe how, and how often, the prosecution utilises the provision. Of particular interest will be the number of initial oral notifications to the granting court, as opposed to formal applications resulting in subsequent reviews.

The impact the Human Rights Act has upon the interpretation and application of the section will also be another area to closely observe.   

Katrina Musgrove
Barrister
Blackburn Chambers

 The position of women in our communities is more frequently a topic of discussion with increasing awareness around issues such as domestic violence and the gender pay gap.  Of course the challenges of being a professional woman are not the litmus test of how far we have to go on the path to achieving equality for all women but they can certainly be a measure of the space that is made for women in professions and institutions - particularly those that have historically been dominated by men.

With so many women in senior and instrumental roles in the legal profession here in the ACT have we moved beyond the need to consider whether we have an equal playing field for women lawyers in Canberra? An objective view would probably say ‘yes’ - we’ve not got a whole lot to be worried about where gender is concerned.  Our Chief Justice, Chief Magistrate and more recently Law Society President are all women.  Women occupy a variety of senior legal roles in government, the community sector and in the administration of our courts across the ACT.  This is undoubtedly instructive of the position of women in our profession generally - but I suggest it doesn’t paint the complete picture.  The litmus test of the health of our local profession from the perspective of gender has to be our most junior, not our most senior, women lawyers.  And it is here perhaps we need to reflect on whether we still have some way to go. It is not just whether women can achieve in our profession but the experience of the path to that achievement that is also important.

At a Law Week event earlier this year on the topic of sexual harassment (attended by only one man) a junior ACT lawyer painted a fairly sad picture of sexual harassment continuing to feature in the careers of junior women in our local profession.  Some of the examples referred to in that law week event and examples that I’ve seen or heard about over the years are shocking in both their nature and their brazen disregard for appropriateness and professional standards.
 
A mentality that sees women objectified survives and perhaps, thrives, because it’s allowed to.  Women who complain about this treatment are often isolated or held up as hysterical shrews who can’t take a joke.  A modern, progressive profession can’t excuse inappropriate behaviour on the basis of age, experience or position and must provide systems that support the making of complaints effectively and efficiently.  In 2012 the Australian Human Rights Commission in its report on their national survey on sexual harassment highlighted the importance of ethical bystander behaviour as an invaluable tool in the prevention of sexual harassment. Bystander intervention can strongly influence appropriate behaviours and relieve complainants of the responsibility to speak out.  To be clear I am not suggesting that this sort of behaviour is a major feature of the culture of our local profession – but we must accept that it is a feature. With the ABC 7:30 report recently revealing a national survey where one in four female barristers and solicitors identified that they had experienced sexual harassment (42% of female barristers in NSW report being on the receiving end of sexual harassment), the challenge for the profession to eradicate this from our ranks is clear.
 
Another crucial marker of the position of women in our local profession is the capacity for us to achieve the hallmarks of success enjoyed by our male counterparts.  An obvious place to look for this, is the number of women who have been elevated to the ranks of senior counsel.  The ACT has not done well here, with only one woman enjoying that status – a sad number really in the year 2016.  To be fair, this is something that plagues almost every jurisdiction across Australia with only around 121 women in Australia taking silk in the last 50 years or so despite the exponential increase in the number of women practicing law over that time.  This is not about ‘merit’ – that argument is just tedious and boring.  This is about women having equal access to good quality work and supportive professional environments that recognise the balancing act that many women perform juggling the pursuit of professional excellence and care giving responsibilities.  In recent times it has been encouraging to see the ACT Bar focus on the number of women at the bar and I hope to see that focus result in an increasing number of young ACT women lawyers seeing the ACT bar as an genuine career pathway.
 
My own view is that we should reflect the rich diversity of the communities we assist and represent -  ultimately, this means more than just a focus on the position of women in our profession – though it is indeed a good place to begin.  A fulfilling career in the law and the pursuit of high achievement should be an option for any law student no matter their gender, culture or socio-economic background.  You can’t be what you can’t see, but that’s perhaps the beginnings of another piece for another edition of the Bar Bulletin ….   The 2016 ACT Women Lawyers gala award night celebrated the achievements of some of our best and brightest local women lawyers, I encourage us all to reflect on the contribution we make to creating a profession that is welcoming, rewarding and inspiring for all practitioners.   We can do better I think and it’s incumbent on all of us to shape a profession in which everyone can thrive.  

 

Each of the above expressions is a colourful okker-idiom for something completely useless.
 
Does Section 33 of the Crimes (Sentencing) Act 2005 provide a further example?
 
Section 33(1)(s) of the Act provides that a court must take into account “any jury recommendation for mercy” if relevant and if known to the court when sentencing for criminal offences.
 

In 37 years of practice I have never seen a jury recommendation for mercy.

 

I know they once existed, in the same way I know that the Australian Rugby Union team once beat the All Blacks at Eden Park but that is about all I know.
 
The legendary English trial advocate Edward Marshall-Hall in 1920 was involved as defence counsel for one of two accused, William Gray, in what became known as “The Crumbles Murder” where there was a recommendation for mercy.
 
Interestingly, Mr Gray’s representation, by arguably the greatest English criminal trial lawyer in the early part of last century, was funded by the weekly news magazine “John Bull” which, from time-to-time advocated for the establishment of a prisoner’s defence fund or, in other words, Legal Aid.
 
Both William Gray and Jack Field, his co-accused, were convicted of murder with a jury recommendation for mercy.
 
The matter went on appeal to the Court of Criminal Appeal in 1921 and was also referred to the Home Secretary because of certain unusual features of the trial.

Most curiously, both Field and Gray gave evidence before the Court of Criminal Appeal.  In doing so they managed to contradict things they had earlier said which, no doubt to some degree, contributed to the circumstances of their final meeting on the 4^th of February 1921 when they were brought from their separate cells at Wandsworth Prison to the scaffold where their double execution took place.
 
It can be safely concluded that the recommendation for mercy was ultimately ignored.
 
In Myerson v R  the High Court came to consider a case in which the accused had been found guilty of three counts of dishonesty but with the rider:
 
“We strongly recommend the accused Maurice Myerson to mercy on account of ill-health, and because we believe he was a tool, an unsuspecting tool, of Abraham, his brother”.
 
It is interesting to consider the form of the first two counts on the Indictment, not only for an appreciation of the arcane legalese in which they were expressed, but to understand the argument which was before the High Court.
 
Count 1 alleged that Meyerson and another (his brother) conspired together to cheat and defraud certain named creditors and others of “divers large quantities of goods and merchandise and divers large sums of money the property of the creditors aforesaid”.
 
Count 2 alleged that the two brothers were, on the 7^th of June 1907, made bankrupt and that on the 1^st of June that year “they, with intent to defraud the same creditors, conspired and agreed together that they should within 4 months before the sequestration order dispose of otherwise than in the ordinary way of trade certain goods and merchandise which they had obtained on credit from the creditors mentioned, and for which they had not paid”.
 
In the High Court Griffith CJ was troubled by the argument that the recommendation to mercy was equivalent to a verdict of not guilty. 
 
His Honour the Chief Justice noted the case of Reg v Trebilcock  in which Lord Campbell CJ expressed doubt whether a rider of a jury recommending a prisoner to mercy ought to be referred to in order to ascertain what the jury meant as it was not part of their finding.
 
His Honour observed, however, that:
 
            “It is the duty of the court, where a jury has found a prisoner guilty and added a rider to their verdict, to look at the whole of the finding, and that if it appears reasonably doubtful, taking the whole finding together, whether the jury have found the facts necessary to establish the offence charged, the accused is entitled to the benefit of the doubt”.
 
Chief Justice Griffith went on to consider in careful detail the words actually employed by the jury, concluding that they were capable of meaning that the accused had not suspected that the enterprise was unlawful. In doing so, His Honour observed “Ignorantia juris haud excusat”.
 
The Chief Justice concluded that the words of the jury rider had to be considered in the circumstances of the particular case and if given their ordinary meaning the accused could not be guilty of the offence then the conviction could not be supported.
 
Bearing in mind that the jury had returned verdicts of guilt His Honour though that “a clear statement or finding of fact is not be cut down by the subsequent use of ambiguous words”.
 
Barton J, O’Connor J and Isaacs J all concurred.
 
In Whittaker v R  Alexander Lindsay Whittaker was charged with the murder of his wife.  The jury acquitted him of murder but found him guilty of manslaughter and added “a strong recommendation to mercy”. 
 
Isaacs J, in what is the leading judgment, held that:
 
            “The verdict of the jury establishing the crime of manslaughter cannot be reduced to comparative innocence by a mere recommendation to mercy”.
 
The question on appeal concerned the adequacy of the sentence which was imposed at first instance, which was a sentence of 12 months imprisonment with hard labour.  The statutory alternatives were penal servitude for life or any term not less than three years or imprisonment for any term not exceeding three years.
 
His Honour added:
 
            “Whatever weight might have been given to the recommendation otherwise, it was in this instance pressed beyond the limits of its proper function.  The recommendation of a jury for leniency should always be treated with respect and careful attention.  It is a recognised feature of our legal system.  But a recommendation simpliciter is, after all, a recommendation only, and the Judge, on whom falls the sole responsibility of measuring the punishment within the limits assigned, must consider for himself how far it is consistent with the demands of justice that he should accede to the recommendation”.
 
Subject to statue judges are required to give juries particulars warnings, such as a Longman warning; a Domican warning; an accomplice warning, and a Pollitt warning, for the purpose of alerting juries to particular difficulties with particulars classes of evidence with which they are unlikely to be familiar.
 
In addition, judges are required to give juries certain ineluctable directions as to matters such as the function of the judge and jury, the burden and standard of proof, what constitutes evidence, the drawing of inferences from direct evidence, the care to be exercised in drawing inferences and, if an inference forms an essential step in the jury’s process of reasoning to guilt, the need to be satisfied of that inference beyond reasonable doubt.
 
In “Australian Criminal Trial Directions” the author, S Tilmouth QC, (now Judge Tilmouth of the South Australian District Court) says this:
 
            “It is clear law that no enquiry should be made of the jury as to reasons for any verdict or recommendation of mercy: R v Wingrove (1936) 56 WN (NSW) 118; R v Black [1963] 1 WLR 1311; R v Tappy [1960] VR 137.  In Black the court expressed the view that a judge should not invite a jury to add a recommendation for mercy to their verdict, obliquely or expressly and in R v Larkin [1943] KB 174; [1943] 1 All ER 217 it was said that neither the judge nor counsel should invite the jury to add recommendations of mercy to their verdict”.
 
Thus, the abject uselessness of Sub-section 33(1)(s) of the Crimes (Sentencing) Act 2005 is demonstrated. 
 
If no-one is entitled to tell a jury about their common law entitlement to recommend mercy then it is highly unlikely that any jury will do so, unless amongst their number is some scholar or legal historian.
 
In this writer’s opinion, it is high time that one of our Justices took the initiative and told a jury about their undoubted right to recommend mercy or one of our number took the even bolder step of referring to that right in a closing address.
 
My suggestion to any criminal barrister faced with a case where a jury recommendation to mercy might be appropriate is not be constrained by the fear of the unknown.
 
I trust this short article might assist he or she with some basic reference material.
 
Let me conclude by saying, “You go first and good luck”.
 
Jack Pappas
Barrister

In the May 2016 edition of ACT Bar Bulletin, an article was published 'Contact Rules - the unacceptable barriers for prisoners and families, at the new Darwin Correctional Precinct'.

The ACT Bar Association would like to acknowledge the writer of the article Amelia Noble.  Amelia  is a final year student at the Australian National University, studying a Bachelor Law (Hons)/Bachelor Music.  Amelia wrote the paper while working as an intern at the North Australian Aboriginal Justice Agency (NAAJA) in Darwin. The views and opinions expressed in the paper are those of the author.  This paper was originally published in ‘Balance’, the Northern Territory Law Society Journal (Edition 1, 2016). The full version (with citations) can be accessed here.

 

Mr Ken Archer, President of the ACT Bar invites Members of the ACT Bar to the Association's Christmas Lunch on Friday 16 December from 12.30pm at University House (Drawing Room). Click here to download your invitation.