The [name withheld] single transaction principle is relatively narrow: temporal and physical proximity alone are insufficient to establish a connected series of events constituting one transaction. Two incidents involving the same accused but different victims, separated by approximately two hours and 2.6 km, with no intervening incidents, do not constitute a single transaction. Critically, the prosecution cannot rely on the subject incident as a robbery to establish the connection between the incidents when robbery is the very fact sought to be proved — this constitutes impermissible bootstraps reasoning. The question of whether double jeopardy considerations apply to the construction of ss 352(1)(ab) and 353(4) of the Criminal Law Consolidation Act 1935 (SA) was expressly left open.
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