A plea of guilty will not preclude an appeal where the plea was induced not by consciousness of guilt but by recognition that a coerced confession could not effectively be challenged. Evidence from the Police Royal Commission demonstrating that arresting officers were prepared to act corruptly in criminal investigations is capable of constituting fresh evidence warranting the quashing of convictions based solely on confessional evidence. Where the only evidence is a confession and the court cannot be satisfied beyond reasonable doubt that it was voluntary, acquittal rather than retrial is the appropriate order.
The full text is available to signed-in members, including the 8 later cases that cite this judgment.
2 of the 8 citing cases carry a classified treatment. How each court treated it is available to signed-in members.