O'Dea v Western AustraliaCitation:[2022] HCA 24Before:Kiefel CJ, Gageler, Gordon, Edelman, Steward JJDate:10 Aug 2022Case Number:P53/2021Read more

O'Dea v Western AustraliaCitation:[2022] HCA 24Before:Kiefel CJ, Gageler, Gordon, Edelman, Steward JJDate:10 Aug 2022Case Number:P53/2021Read more

Section 7(a) does not permit the acts of one person to be attributed to another for the purposes of criminal responsibility as a principal offender; each accused must have personally done the act or acts constituting the offence. The trial judge's direction to the jury was erroneous and occasioned a miscarriage of justice.

Parties
Appellant: Appellant; Co Accused: Co-accused
Jurisdiction
Australia
Judgment Date
10 August 2022
Procedural Posture
Criminal / Judgment
Outcome
appeal allowed
Legal Topics
Parties to Offence, Principal Offenders, Grievous Bodily Harm, Attribution of Acts, Jury Directions

Case Brief

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Parties

Appellant

Appellant

Co-accused

Co Accused

Procedural Posture

Criminal / Judgment

  1. 1 Whether s 7(a) of the Criminal Code (WA) permits acts of one person to be attributed to another for the purposes of criminal responsibility as a principal offender
  2. 2 Whether the trial judge's direction to the jury regarding acting in concert and attribution of acts occasioned a miscarriage of justice

Ratio Decidendi

Section 7(a) does not permit the acts of one person to be attributed to another for the purposes of criminal responsibility as a principal offender; each accused must have personally done the act or acts constituting the offence. The trial judge's direction to the jury was erroneous and occasioned a miscarriage of justice.

Court Disposition

appeal allowed

Orders

  • Conviction quashed
  • New trial ordered