Riddle v R [1911] HCA 33

Riddle v R [1911] HCA 33

Section 407 of the Crimes Act 1900 (NSW) unambiguously provides that a wife is competent but not compellable to give evidence against her husband in criminal proceedings. There is no statutory or common law basis to compel her testimony where she objects. The trial judge erred in compelling the wife to give evidence; the conviction should be set aside.

Parties
Appellant: John Thomas Riddle; Respondent: The King
Jurisdiction
Australia
Judgment Date
04 August 1911
Procedural Posture
Criminal Appeal / High Court Appeal From Supreme Court of New South Wales
Outcome
appeal allowed; conviction set aside
Legal Topics
Competency and Compellability of Spouses as Witnesses, Statutory Interpretation, Crimes Act 1900 (nsw) S 407

Case Brief

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Parties

John Thomas Riddle

Appellant

The King

Respondent

Procedural Posture

Criminal Appeal / High Court Appeal From Supreme Court of New South Wales

  1. 1 Whether, under s 407 Crimes Act 1900 (NSW), a wife is compellable to give evidence against her husband in a criminal proceeding where he is charged with wounding her
  2. 2 Whether the trial judge erred in compelling the wife to give evidence against her husband

Ratio Decidendi

Section 407 of the Crimes Act 1900 (NSW) unambiguously provides that a wife is competent but not compellable to give evidence against her husband in criminal proceedings. There is no statutory or common law basis to compel her testimony where she objects. The trial judge erred in compelling the wife to give evidence; the conviction should be set aside.

Court Disposition

appeal allowed; conviction set aside

Orders

  • Conviction quashed