McDonald v R [2010] NSWCCA 220

McDonald v R [2010] NSWCCA 220

The trial judge appropriately directed that malice could be established by recklessness but intent to cause grievous bodily harm must also be proved beyond reasonable doubt, with appropriate consideration given to intoxication; directions regarding self-defence correctly placed the onus on the Crown to disprove the defence beyond reasonable doubt.

Jurisdiction
Australia
Judgment Date
30 September 2010
Procedural Posture
Conviction Appeal / Judgment After Hearing
Outcome
Appeal dismissed
Legal Topics
['conviction Appeal' 'wounding With Intent' 'self Defence' 'jury Directions' 'onus of Proof']

Case Brief

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Procedural Posture

Conviction Appeal / Judgment After Hearing

  1. 1 ['Whether the trial judge erroneously directed jury that conviction could be based on recklessness for intent to cause grievous bodily harm under s 33 Crimes Act 1900' 'Whether the trial judge correctly directed jury on need to find both malice and intent to cause grievous bodily harm' 'Whether the trial judge reversed or misdirected the onus of proof in relation to self-defence under s 419 Crimes Act 1900']

Ratio Decidendi

The trial judge appropriately directed that malice could be established by recklessness but intent to cause grievous bodily harm must also be proved beyond reasonable doubt, with appropriate consideration given to intoxication; directions regarding self-defence correctly placed the onus on the Crown to disprove the defence beyond reasonable doubt.

Court Disposition

Appeal dismissed

Orders

  • ['Leave to rely upon Grounds 1 and 2 of the Notice of Appeal is refused' 'Appeal dismissed']