The Court permitted the Crown to adduce both coincidence evidence (relating to an alleged unregistered remittance network involving cash handovers and international money transfers across counts 1–6) and tendency evidence (relating to the accused's pattern of purchasing luxury goods wholly or substantially in cash across counts 7–8) at trial for Commonwealth proceeds of crime offences. Slattery AJ held that the coincidence evidence had significant probative value because the similarities across the transactions — including the people giving instructions, entities used, creation of false invoices, and arranging of cash handovers — were so stark and distinct that the improbability of coincidental occurrence was established, and that the tendency evidence strongly supported proof of the accused's state of mind regarding proceeds of crime, with the probative value outweighing any danger of unfair prejudice in both instances. The tendency notice was admitted as amended by removal of paragraph (2)(b)(iii) concerning recklessness as to concealment or disguise.
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