Flavell v R [2008] NSWCCA 223

Flavell v R [2008] NSWCCA 223

An offence against s 86 Crimes Act (kidnapping) can be committed by denying access to third persons to another person, in circumstances where the other person is incapable of helping themselves, thereby causing the victim to remain where they are. Whether the offence is proven on the facts is a matter for the jury.

Parties
Applicant: Glenn Samual Flavell; Respondent: The Crown
Jurisdiction
Australia
Judgment Date
25 September 2008
Procedural Posture
Criminal Appeal / Leave to Appeal and Appeal Against Interlocutory Judgment or Order
Outcome
Leave granted; appeal dismissed.
Legal Topics
Kidnapping, Permanent Stay of Proceedings, Interpretation of 'detaining' Under Crimes Act S86, Interference With Liberty, Detaining Unconscious Persons

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Parties

Glenn Samual Flavell

Applicant

The Crown

Respondent

Procedural Posture

Criminal Appeal / Leave to Appeal and Appeal Against Interlocutory Judgment or Order

  1. 1 Whether evidence was capable of constituting the elements of the offence of kidnapping
  2. 2 Whether 'detaining' includes preventing access by others to assist an unconscious victim
  3. 3 Whether victim's liberty was restrained

Ratio Decidendi

An offence against s 86 Crimes Act (kidnapping) can be committed by denying access to third persons to another person, in circumstances where the other person is incapable of helping themselves, thereby causing the victim to remain where they are. Whether the offence is proven on the facts is a matter for the jury.

Court Disposition

Leave granted; appeal dismissed.

Orders

  • Leave to appeal granted.
  • Appeal dismissed.