Hough v Ah Sam [1912] HCA 78

Hough v Ah Sam [1912] HCA 78

Statements made by the accused in response to questions from customs officers, in the absence of threat or inducement, are admissible as evidence, and, in conjunction with the other circumstances, form sufficient evidence for the magistrate to be justified in finding that the opium was imported in contravention of the Customs Act.

Parties
Appellant: Hover; Respondent: Ah Sam
Jurisdiction
Australia
Judgment Date
08 November 1912
Procedural Posture
Criminal Appeal / Appeal to High Court of Australia From Supreme Court of Western Australia
Outcome
appeal allowed
Legal Topics
Admissibility of Evidence, Confessions, Prohibited Imports, Onus of Proof, Possession Offences

Case Brief

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Parties

Hover

Appellant

Ah Sam

Respondent

Procedural Posture

Criminal Appeal / Appeal to High Court of Australia From Supreme Court of Western Australia

  1. 1 Whether answers provided by the accused to questions from customs officers are admissible as evidence at trial
  2. 2 Whether there was sufficient evidence of importation of prohibited goods under the Customs Act 1901-1910

Ratio Decidendi

Statements made by the accused in response to questions from customs officers, in the absence of threat or inducement, are admissible as evidence, and, in conjunction with the other circumstances, form sufficient evidence for the magistrate to be justified in finding that the opium was imported in contravention of the Customs Act.

Court Disposition

appeal allowed

Orders

  • Order of the Supreme Court of Western Australia quashing the conviction is discharged.
  • Appeal to the Supreme Court is dismissed.