Fantakis v R (No 2) [2023] NSWCCA 22

Fantakis v R (No 2) [2023] NSWCCA 22

The Court held that the alternative timeframes presented by the Crown did not amount to reliance on distinct acts capable of founding separate bases for conviction; the case involved a single alleged act (murder by force), with uncertainty only as to when this act occurred. Therefore, there was no requirement for a unanimity direction and the additional ground of appeal fails.

Jurisdiction
Australia
Judgment Date
15 February 2023
Procedural Posture
Criminal Appeal / Application to Vary or Set Aside Prior Appellate Orders
Outcome
Application dismissed
Legal Topics
['unanimity Direction' 'misdirection' 'murder' 'appeal Procedure' 'grounds of Appeal' 'consequential Orders']

Case Brief

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Procedural Posture

Criminal Appeal / Application to Vary or Set Aside Prior Appellate Orders

  1. 1 ['Whether the trial judge erred by failing to give a unanimity direction to the jury where alternative factual scenarios (case theories) were presented by the Crown.' 'Whether the omission of a unanimity direction occasioned a substantial miscarriage of justice.']

Ratio Decidendi

The Court held that the alternative timeframes presented by the Crown did not amount to reliance on distinct acts capable of founding separate bases for conviction; the case involved a single alleged act (murder by force), with uncertainty only as to when this act occurred. Therefore, there was no requirement for a unanimity direction and the additional ground of appeal fails.

Court Disposition

Application dismissed

Orders

  • ['The application to set aside or vary the orders made by the Court on 3 February 2023 is dismissed.']