The Supreme Court dismissed an appeal against conviction for aggravated assault occasioning actual bodily harm, holding that even if the appellant genuinely believed he was unlawfully confined in a vehicle, striking the complainant repeatedly in the face with significant force while she was driving could not objectively constitute a reasonable response in self-defence under Zecevic. The Court accepted, without definitively resolving, that unlawful confinement may ground a common law self-defence claim, but found the second limb of the Zecevic test (reasonable grounds for the belief that the response was necessary) was not satisfied on the evidence. The Court also held that the Chief Magistrate's good character direction, Murray direction, and Liberato direction were not misapplied, and that findings of manipulative behaviour and a broken nose were open on the evidence.
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