Whether a document is 'required for any accounting purpose' under s.83(1) of the Crimes Act 1958 (Vic) depends on: (i) the nature of the document, (ii) the use for which it was made or required by the person to whom it was produced, and (iii) the evidence upon which the fact-finder could conclude it was required for an accounting purpose. A document may have a dual purpose — one non-accounting and one accounting — and still fall within the section. Valuation reports for mortgage lending may qualify where they are used to calculate loan-to-valuation ratios. The accomplice warning rule in Davies v DPP applies only where the witness was participes criminis in respect of the actual crime charged.
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