R v MK [2020] NSWDC 658

R v MK [2020] NSWDC 658

The Queensland allegations were not admissible as tendency evidence as they lacked significant probative value due to the gap in time, difference in context, and the high level of generality of the alleged tendency; Dr Shackel's report was inadmissible as she lacked the required expertise in child psychology or psychiatry, despite the relevance of the literature reviewed.

Jurisdiction
Australia
Judgment Date
06 October 2020
Procedural Posture
Criminal / Interlocutory Ruling on Admissibility of Evidence
Outcome
Application to admit tendency and expert evidence refused
Legal Topics
['tendency Evidence' 'expert Evidence' 'sexual Offences' 'admissibility of Evidence']

Case Brief

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Procedural Posture

Criminal / Interlocutory Ruling on Admissibility of Evidence

  1. 1 ['Whether Queensland allegations are admissible as tendency evidence in proof of New South Wales offences' "Whether Dr Shackel's expert report is admissible as expert evidence regarding child sexual abuse complainant behaviour"]

Ratio Decidendi

The Queensland allegations were not admissible as tendency evidence as they lacked significant probative value due to the gap in time, difference in context, and the high level of generality of the alleged tendency; Dr Shackel's report was inadmissible as she lacked the required expertise in child psychology or psychiatry, despite the relevance of the literature reviewed.

Court Disposition

Application to admit tendency and expert evidence refused

Orders

  • ['Evidence of the Queensland allegations is not admitted as tendency evidence.' 'Report of Dr Shackel is not admitted as expert evidence.']