Environment Protection Authority v Truegain Pty Ltd [No 2] [2012] NSWLEC 55

Environment Protection Authority v Truegain Pty Ltd [No 2] [2012] NSWLEC 55

A summons that alleges two particulars each constituting a separate failure under environmental law is duplicitous. The prosecutor must elect which specific alleged failure to pursue, as each represents a distinct offence and cannot be combined under a single charge.

Jurisdiction
Australia
Judgment Date
20 March 2012
Procedural Posture
Criminal Prosecution / Interlocutory Decision Regarding Duplicity and Particulars in a Summons
Outcome
Prosecutor must elect which particular it wishes to pursue; the particulars as combined are bad for duplicity.
Legal Topics
['duplicity in Summons' 'particulars of Criminal Charges' 'protection of the Environment Operations Act']

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Procedural Posture

Criminal Prosecution / Interlocutory Decision Regarding Duplicity and Particulars in a Summons

  1. 1 ['Whether the particulars in the prosecution summons are bad for duplicity' 'Whether the prosecutor can rely on more than one distinct failure under one charge']

Ratio Decidendi

A summons that alleges two particulars each constituting a separate failure under environmental law is duplicitous. The prosecutor must elect which specific alleged failure to pursue, as each represents a distinct offence and cannot be combined under a single charge.

Court Disposition

Prosecutor must elect which particular it wishes to pursue; the particulars as combined are bad for duplicity.

Orders

  • ['Prosecutor to elect as to which of the two particulars ((c)(iv) or (v)) it will proceed with.']