MDP v The KingCitation:[2025] HCA 24Before:Gageler CJ, Gordon, Edelman, Steward, Gleeson, Jagot, Beech-Jones JJDate:18 Jun 2025Case Number:B72/2023Read more

MDP v The KingCitation:[2025] HCA 24Before:Gageler CJ, Gordon, Edelman, Steward, Gleeson, Jagot, Beech-Jones JJDate:18 Jun 2025Case Number:B72/2023Read more

The Court held that the admission of the evidence and the direction to the jury were wrong decisions on questions of law, but those errors were not material and did not occasion a substantial miscarriage of justice.

Parties
Appellant: MDP; Respondent: The King
Jurisdiction
Australia
Judgment Date
18 June 2025
Procedural Posture
Criminal Appeal / Judgment
Outcome
appeal dismissed
Legal Topics
Appeal, Wrong Decision on Question of Law, Sexual Offences, Propensity Evidence, Jury Directions, Substantial Miscarriage of Justice

Case Brief

Summary, issues, holding and outcome

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Parties

MDP

Appellant

The King

Respondent

Procedural Posture

Criminal Appeal / Judgment

  1. 1 Whether the admission of evidence of smacking complainant's backside as evidence of sexual interest was a wrong decision on a question of law
  2. 2 Whether the direction to the jury permitting use of that evidence as propensity evidence was a wrong decision on a question of law
  3. 3 Whether a wrong decision on a question of law has a materiality threshold

Ratio Decidendi

The Court held that the admission of the evidence and the direction to the jury were wrong decisions on questions of law, but those errors were not material and did not occasion a substantial miscarriage of justice.

Court Disposition

appeal dismissed

Orders

  • The appeal is dismissed.