The Court of Appeal dismissed both applications for bail pending appeal against conviction and sentence, finding that the self-represented appellant failed to establish exceptional reasons under cl 4A of sch 1 pt C of the Bail Act 1982 (WA). The Court held that difficulties common to all persons in custody — including limited access to electronic resources, library facilities, and prison conditions — cannot constitute exceptional reasons for bail. The Court also held that the proposed grounds of appeal, which primarily challenged the validity of plant identification certificates and sought to impugn guilty pleas entered with legal representation, were not sufficiently strong at this preliminary stage to justify bail, particularly given the considerable obstacle that convictions followed pleas of guilty.
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