PRINCIPLES GOVERNING THE CONDUCT OF A DEFENCE

Before I embark on a consideration of the whole of the evidence in order to decide whether the prosecution has proved its case beyond reasonable doubt I consider it necessary to refer to some principles governing the conduct of a defence.

If the accused intends to suggest that a prosecution witness is not speaking the truth on a particular point the witness’s attention must be directed to that fact in cross-examination. In support I can do no better than refer to the words of Lord Chancellor Herschell in Browne v Dunn (1893) 6 R 69 where his Lordship said at p 70,

"Now, My Lords, I cannot help saying that it seems to me to be absolutely essential to the proper conduct of a cause where it is intended to suggest that a witness is not speaking the truth on a particular point, to direct his attention to the fact, by some questions put in cross-examination showing that that imputation is intended to be made, and not to take his evidence and pass it by as a matter altogether unchallenged and then, when it is impossible for him to explain, as perhaps he might have been to do if such questions had been put to him, the circumstances which it is suggested indicate that the story he tells ought not to be believed, to argue that he is a witness unworthy of credit. My Lords, I have always understood that if you intend to impeach a witness you are bound, whilst he is in the box, to give him an opportunity of making any explanation which is open to him, and, as it seems to me, that is not only a rule of professional practice in the conduct of a case, but is essential to fair play and fair dealing with witnesses." The effect of a failure to cross-examine a witness on a material point was lucidly explained by Raja Azlan Shah CJ (Malaya) (as His Highness then was) in speaking for the Federal Court in Wong Swee Chin v PP (1981) 1 MLJ 212 at p 213 in the following terse words, "Mr Jagjit Singh also raised as one of his main grounds of appeal that the trial judge erred in law when he held that the failure of the defence to cross-examine the two prosecution witnesses on the ammunition actually found in the trouser pockets of the appellant at the time of his arrest (the subject-matter of the trial charge) consituted a clear admission of the charge of possession by the appellant. We consider that statement of the law as a misdirection. A correct statement of the law is that failure of the defence to cross-examine the prosecution witnesses on the matter merely goes to the credibility of their testimony, to wit, the fact that they found the ammunition in the appellant’s trouser pockets remains unshaken. On this point we need only say there is a general rule that failure to cross-examine a witness on a crucial part of the case will amount to an acceptance of the witness’s testimony. But as is common with all general rules there are also exceptions as pointed out in the judgment of the Supreme Court of New Zealand in Transport Ministry v Garry (1973) 1 NZLR 120 where Haslam J said at page 122:- ‘In Phipson on Evidence 11th edition paragraph 1544 the learned authors suggest examples by way of exception to the general principle that failure to cross-examine will amount to an acceptance of the witness’s testimony, viz, where ‘ … the story is itself of an incredible or romancing character, or the abstention arises from mere motives of delicacy … or when counsel indicates that he is merely abstaining for convenience, e.g., to save time. And where several witnesses are called to the same point it is not always necessary to cross-examine them all’ ." The nature of the defence is to be ascertained not only from the evidence of the accused himself but also from the trend of the cross-examination of the prosecution witnesses and from the arguments of the accused’s counsel at the close of the trial (see Kuli and Ors v Emperor AIR 1930 Cal 442). It is therefore important for the accused to put his essential and material case to the prosecution witnesses in cross-examination. This is a principle of essential justice and was neatly stated by Mukhrji J in AEG Carapiet v AY Derderian AIR 1961 in the following terms: "The law is clear on the subject. Wherever the opponent has declined to avail himself of the opportunity to put his essential and material case in cross-examination, it must follow that he believed that the testimony given could not be disputed at all. It is wrong to think that this is merely a technical rule of evidence. It is a rule of essential justice. It serves to prevent surprise at trial and miscarriage of justice, because it gives notice to the other side of the actual case that is going to be made when the turn of the party on whose behalf the cross-examination is being made comes to give and lead evidence by producing witnesses. It has been stated on high authority of the House of Lords that this much a counsel is bound to do when cross-examining that he must put to each of his opponent’s witnesses in turn, so much of his own case as concerns that particular witness or in which that witness had any share. If he asks no question with regard to this, then he must be taken to accept the plaintiff’s account in its entirety. Such failure leads to miscarriage of justice, first by springing surprise upon the party when he has finished the evidence of his witnesses and when he has no further chance to meet the new case made which was never put and secondly, because such subsequent testimony has no chance of being tested and corroborated." On the effect of a failure by the defence to put its case to the prosecution witnesses useful reference may be made to Alcontara a/l Ambross Anthony v PP (1996) 1 MLJ 209 where Edgar Joseph Jr FCJ said at p 218, "Speaking generally, in a criminal trial, the whole point and purpose of the defence having to put its case to such of the prosecution witnesses as might be in a position to admit or deny it, is to enable the prosecution to check on whether an accused’s version of the facts is true or false, and thus avoid the adverse comment, that the defence is a recent invention — in other words, ‘kept up its sleeve’, as it were — and revealed for the first time when the accused makes his defence from the witness box or the dock, thus detracting from the weight to be accorded to the defence. However, failure on the part of the defence, as aforesaid, can never, by itself, relieve the prosecution of its duties of establishing the charge against the accused beyond reasonable doubt.

… it is settled law that, although a court may view with suspicion a defence which has not been put to the appropriate prosecution witnesses who might have personal knowledge of the points at issue, the court is still bound to consider the defence, however weak, and to acquit if not satisfied that the prosecution has discharged the burden of proof which tests upon it."

The position is, however, different when the new defence raised could not have been raised at an earlier stage (see Emperor v Kameshwan Lal & Ors AIR 1933 Pat 481).

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