R v Dawson [2022] NSWSC 861

R v Dawson [2022] NSWSC 861

There was no impropriety in the way the Family Court documents were obtained, the Harman principle does not prevent their admission as they were received into evidence in prior proceedings, and their use by the Crown is not unfair to the accused. Therefore, the documents are admissible.

Jurisdiction
Australia
Judgment Date
01 July 2022
Procedural Posture
Criminal / Procedural Ruling During Murder Trial
Outcome
Application to exclude documents dismissed; documents admitted as Exhibit CU.
Legal Topics
['murder' 'admissibility of Evidence' 'improperly Obtained Evidence' 'harman Principle' 'unfairness of Admissions']

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Procedural Posture

Criminal / Procedural Ruling During Murder Trial

  1. 1 ['Whether Family Court documents relied on by the Crown are inadmissible under s 138 of the Evidence Act 1995 (NSW) for being improperly obtained or as a consequence of impropriety' 'Whether tender of the Family Court documents breaches the Harman principle' 'Whether the use of admissions in the documents by the Crown would be unfair to the accused and should be excluded under s 90 of the Evidence Act 1995 (NSW)']

Ratio Decidendi

There was no impropriety in the way the Family Court documents were obtained, the Harman principle does not prevent their admission as they were received into evidence in prior proceedings, and their use by the Crown is not unfair to the accused. Therefore, the documents are admissible.

Court Disposition

Application to exclude documents dismissed; documents admitted as Exhibit CU.

Orders

  • ['Admit the documents from the Family Court as Exhibit CU.']