R. v. Wright

R. v. Wright

Although the trial judge erred by referring to the complainant's diary not admitted in evidence, that error did not cause a substantial wrong or miscarriage of justice; the Court of Appeal properly applied the curative proviso in s.686(1)(b)(iii) and therefore the appeal is dismissed and the convictions are upheld.

Source-derived case information.

Citation
[1996] 2 SCR 163
Parties
Appellant: Robert Wright; Respondent: Her Majesty The Queen
Court
Supreme Court of Canada
Jurisdiction
Canada
Judgment Date
22 May 1996
Procedural Posture
Criminal Appeal / Appeal to Supreme Court of Canada From Ontario Court of Appeal
Outcome
Appeal dismissed; convictions for sexual assault and sexual interference upheld.
Legal Topics
Sexual Assault, Corroboration, Curative Proviso S.686(1)(b)(iii)
Source Language
english
Criminal Law Evidence Sexual Assault Corroboration Curative Proviso S.686(1)(b)(iii)

Source-derived case record

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Parties

Robert Wright

Appellant

Her Majesty The Queen

Respondent

Procedural Posture

Criminal Appeal / Appeal to Supreme Court of Canada From Ontario Court of Appeal

  1. 1 Whether the trial judge erred by relying on the complainant's diary that had not been admitted into evidence as corroboration of her testimony
  2. 2 Whether the Court of Appeal erred in applying the curative proviso s.686(1)(b)(iii) to uphold the conviction

Ratio Decidendi

Although the trial judge erred by referring to the complainant's diary not admitted in evidence, that error did not cause a substantial wrong or miscarriage of justice; the Court of Appeal properly applied the curative proviso in s.686(1)(b)(iii) and therefore the appeal is dismissed and the convictions are upheld.

Court Disposition

Appeal dismissed; convictions for sexual assault and sexual interference upheld.

Orders

  • Appeal dismissed
  • Judgment of the Ontario Court of Appeal affirmed