A single count of defrauding the Commonwealth under s 29D of the Crimes Act 1914 (Cth) may properly allege a criminal enterprise encompassing multiple acts of dishonesty over an extended period, provided the acts can fairly and properly be identified as part of the same criminal enterprise. The Crown need not prove every act relied upon but must prove sufficient acts to constitute the enterprise beyond reasonable doubt. The broad language of s 29D supports enterprise counts in a way that provisions using words of singularity (such as those considered in Walsh v Tattersall and Giam) do not.
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