Ivan Raymond Williams v the Queen [1979] FCA 14
The convictions and sentences for attempted bribery stand as s.73 of the Crimes Act 1914 applies to any conferring of benefit in respect of an act by the officer, not limited to corrupt purpose; however, the conviction for conspiracy is set aside due to insufficient jury direction on the relationship between the findings necessary for each charge, risking inconsistent verdicts.
- Parties
- Appellant: Ivan Raymond Williams; Respondent: The Queen
- Jurisdiction
- Australia
- Judgment Date
- 02 March 1979
- Procedural Posture
- Criminal Appeal / Appeal From Conviction and Sentence
- Outcome
- Appeal against conviction on conspiracy charge upheld; other convictions affirmed
- Legal Topics
- Bribery, Conspiracy, Jury Directions
Case Brief
Summary, issues, holding and outcome
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Parties
Ivan Raymond Williams
Appellant
The Queen
Respondent
Procedural Posture
Criminal Appeal / Appeal From Conviction and Sentence
Legal Issues
- 1 Proper construction of s.73 Crimes Act 1914 (Cth) regarding bribery of Commonwealth officers
- 2 Requirement of corrupt purpose for offence under s.73
- 3 Whether jury directions were misleading regarding common facts to charges with different verdicts
Ratio Decidendi
The convictions and sentences for attempted bribery stand as s.73 of the Crimes Act 1914 applies to any conferring of benefit in respect of an act by the officer, not limited to corrupt purpose; however, the conviction for conspiracy is set aside due to insufficient jury direction on the relationship between the findings necessary for each charge, risking inconsistent verdicts.
Court Disposition
Appeal against conviction on conspiracy charge upheld; other convictions affirmed
Orders
- The convictions and sentences in respect of the charges of attempted bribery are affirmed.
- The appeal against the conviction on the charge of conspiracy is upheld.
Full Case Text
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