The Court held that where a prosecution relies on evidentiary certificates under ss 79B and 175 of the Road Traffic Act 1961 (SA), there is no obligation to disclose underlying testing documentation, operator running sheets, or metadata unless such documents exist and disclose a basis for rebutting the statutory presumptions. The burden of demonstrating that disclosure is incomplete, and that an adjournment is warranted, lies on the party asserting incompleteness; a bare assertion of wanting 'full disclosure' without identifying specific omissions is insufficient. The Court also held that a magistrate's refusal of an adjournment application followed by immediate commencement of trial does not give rise to apprehended bias, and that references to procedural directions given at pre-trial conferences do not breach Joint Criminal Rules 2022 (SA) r 76.3(5).
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