The Royal Prerogative of Mercy

A Review of New Zealand Practice


This paper was prepared by Mr Neville Trendle
in consultation with the Ministry of Justice


(This web version has changed page number references
in the original to Section Title references)


Please send submissions to:
Alison Stephens
Principal Adviser

Ministry of Justice
PO Box 180
WELLINGTON


Fax: 04 494 9917
Electronic copies to:
Alison.stephens@justice.govt.nz

We are happy to meet you to discuss the process.
Please ring Alison: 04 494 9745


Submissions due by 16 May 2003



Confidential Draft Only - This paper does not constitute Government Policy


The Royal Prerogative of Mercy: A Review of New Zealand Practice



CONTENTS



Executive Summary

Introduction

Background

·           The nature of the Royal prerogative of mercy

·           Pardon – section 407 Crimes Act 1961

·           Miscarriages of justice – section 406 Crimes Act 1961

 

The Current Process

·           How applications are considered

·           Threshold for considering applications

·           Procedure within the Ministry of Justice

·           Analysis of applications since 1996

 

Judicial Review

 

Overseas Models

·           Australia
Victoria
New South Wales

·           Canada

·           England

·           Scotland

 

Issues

·           Role of the Minister of Justice

·           Work practice issues
Investigations and Inquiries

·           The transparency of the Ministry’s processes
Determining when and how to exercise the Royal prerogative of mercy
Case priority
Communication with applicants

·           The impact of unrepresented applicants

·           The role of the Court of Appeal

 

Options

·           Ministry of Justice Unit

·           Independent Board

 

Proposal


Compensation for persons wrongly convicted


Appendices


 


The Royal Prerogative of Mercy: A Review of New Zealand Practice

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EXECUTIVE SUMMARY


The Royal Prerogative of Mercy is an important safeguard in our criminal justice system.  It provides an avenue for convicted persons to petition the Crown for relief in cases where an injustice may have occurred. It is usually sought after all appeal rights have been exhausted. It enables the Governor-General to provide a remedy to pardon a convicted offender; to remit or grant respite from the sentence imposed; or to refer all or part of a case to the Court for further review. It is an exercise of clemency that acknowledges that the judicial process with its reliance on rules of evidence and procedure can occasionally be fallible.

An increase in the number and complexity of applications over the last five years prompted this review. Additionally, some overseas jurisdictions have introduced new procedures to deal with such cases.  It is important for the maintenance of public confidence in the criminal justice system that the process for considering applications for the exercise of the Royal prerogative of mercy is reviewed on occasions to ensure that it remains relevant to society’s socio-legal values.

The Background describes the status of the Royal prerogative of mercy. In New Zealand, the prerogative is exercised by the Governor-General by virtue of a delegation in the Letters Patent Constituting the Office of Governor-General.   Sections 406 and 407 of the Crimes Act 1961 provide a statutory adjunct.  Since 1945, Parliament has empowered the Governor-General, when considering an application for exercise of the prerogative of mercy, to refer the question of the applicant’s conviction or sentence to the Court of Appeal or the High Court, or to seek the Court of Appeal’s assistance on any point arising in the case.  Since 1963 the Court of Appeal has considered on a number of occasions the scope of sections 406 and 407, and the procedure to be followed.  The paper outlines the main points to emerge from the Court’s decisions (refer section Background - Miscarriages of justice).

How applications are considered is discussed under the heading The Current Process. The Governor-General receives applications for the exercise of the prerogative of mercy and refers them to the Minister of Justice for consideration. If the Minister of Justice recommends granting a pardon, or referring the case to the Court under section 406 Crimes Act, then the advice is accompanied by an Order in Council. If the Governor-General accepts the advice, the matter is formalised at a subsequent meeting of the Executive Council with the Governor-General signing the Order in Council.

Legal advisers at the Ministry of Justice analyse and consider all applications for the exercise of the prerogative of mercy.  Each application is unique.  In some cases it is apparent that the application does not reach the threshold for the prerogative of mercy to be exercised.  Other cases raise complex or numerous issues that can take months to work through.  Usually it will be necessary to obtain the relevant court file, and to seek further information from the applicant.  Occasionally the advisers will seek the police investigation file; obtain specialist legal or non-legal advice, for example, from an independent barrister or a forensic scientist; or ask the Police or an independent barrister to interview or reinterview witnesses.

Since 1996, 63 applications for the exercise of the prerogative of mercy have been received. As at 30 June 2002, a decision had been made in 47 applications.  Of those, 7 resulted in a reference to the Court in terms of s 406 Crimes Act 1961, the terms of reference of an existing reference were widened in one case, and a Ministerial inquiry held in another.  No pardons were granted, and 38 applications were declined.  As at 30 June 2002, 16 applications were still under consideration.

Under the heading of Judicial Review the paper notes that up to now the exercise of the Royal prerogative of mercy has not been judicially reviewed.  It is, however, recognised that in principle there is no reason why the procedure followed in exercising the prerogative of mercy should not be open to judicial review.

What happens in overseas jurisdictions is the subject of Overseas Models.  The framework for considering applications for the Royal prerogative of mercy in New Zealand is similar to that of other commonwealth countries such as Australia, Canada, England and Scotland. In these jurisdictions the delegated or common law prerogative to pardon has also been supplemented by a statutory scheme providing for reference by the Executive to the Court to revisit a conviction or sentence, or to provide an opinion on an aspect of the case to the Executive.  We examined these countries’ processes to see if they could provide some insights as to how to improve the way we do things here.

For example, a procedure unique to New South Wales allows the appointment of a judicial officer to conduct an inquiry with powers similar to a commission of inquiry.  The inquiry can also refer the question of whether the conviction should be quashed to the Court, if the inquiry is of the opinion that there is a reasonable doubt as to the guilt of the convicted person.

In England, the Royal Commission on Criminal Justice (the Runciman Commission) was established in 1991, after a series of highly publicised cases arising during the 1980’s in which miscarriages of justice occurred coupled with concerns about the efficacy of the prerogative of mercy process.

In its report to Parliament in 1993, the Commission recommended that the responsibility for reviewing allegations of a miscarriage of justice be removed from the Home Secretary and transferred to an independent authority to be established.  The major consideration that led to this recommendation was the Commission’s belief that the role assigned to the Home Secretary to refer cases to the Court was inconsistent with the separation of powers as between the courts and the executive.   The “scrupulous” observance of constitutional principle led to a reluctance on the part of the Home Office to inquire deeply enough into the applications it received.

Effect was given to the Runciman Commission’s recommendation with the passage of the Criminal Appeal Act 1995, and the establishment of the Criminal Cases Review Commission.  Its responsibilities are discussed on page 10.

Until 1999, the process for considering applications for the exercise of the prerogative of mercy in Scotland was similar to the previous process followed in England.  The Sutherland Committee was established in 1994 to look into procedures surrounding appeals and alleged miscarriages of justice.  Like the Runciman Committee, this Committee was influenced by the argument that the role of the executive in considering such cases was incompatible with the constitutional separation of powers between itself and the courts.  It proposed the establishment of a new, independent body with powers to consider alleged miscarriages of justice and to refer deserving cases to the Appeal Court for determination. 



Next, the paper identifies Issues relating to:

 

·           the role of the Minister of Justice  

·           the Ministry’s work practice, particularly in regard to investigations and inquiries

·           the transparency of the Ministry’s process, particularly as to how it applies the criteria for referral or for pardon to cases; how it determines case priority; and communication with applicants; and the

·           the impact of unrepresented applicants.


Lynley Hood’s critique of the Court of the Appeal and the Ministry’s response is also outlined under Issues.

Under Options and Proposal the Ministry seeks views on the principles applied, and the strengths and weaknesses of the two options outlined.  The options are a Ministry of Justice Unit, or a Board of three or four part time members, chaired by a former Judge and including members of high standing in the community.  The Ministry indicates its preference for an independent board, but seeks views on this option.

Finally, the paper discusses the matter of compensation for the wrongfully imprisoned, noting that if a Board is established then it could have responsibility for the administration of compensation.




Submissions

Ministry welcomes comments on any aspect of the paper by 16 May and most particularly on the following issues:

·           The constitutionality of the role of the Minister of Justice providing the Governor General with advice on applications seeking the Royal prerogative of mercy

·           The different approaches to determining the threshold applications have to meet in order to establish that a miscarriage of justice has taken place

·           The proposals that relate to enhancing the administrative practices of the Ministry, and whether the process should have equivalent powers to Commissions of Inquiry

·           The role of the Court of Appeal in the Royal prerogative process as queried by Lynley Hood’s book “A City Possessed

·           The options proposed, that is: (i) to establish a small, dedicated unit in the Ministry of Justice; or (ii) to establish a Board of three i.e. one former Judge as Chair and two other members

·           Whether an independent board should also be responsible for determining compensation matters, and if so whether it should be tasked with making the decision or making a recommendation to the Minister of Justice.





The Royal Prerogative of Mercy: A Review of New Zealand Practice

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INTRODUCTION


The Royal Prerogative of Mercy is an important safety net in our criminal justice system.  It provides an avenue for persons convicted in the Courts to petition the Crown for relief in cases where an injustice may have occurred.  It enables the Governor-General to provide a remedy in one of three ways: firstly to pardon a convicted offender; secondly to remit or grant respite from the sentence imposed; and thirdly to refer the case itself, either in whole or in part, to the Court for further review.

The prerogative of mercy is not a final right of appeal from court decisions – indeed it is usually sought after all appeal rights have been exhausted.  It is available in those rare cases where a miscarriage of justice may have arisen through the disposition of the case in the courts, or where there are other grounds for the exercise of mercy. 

An increase in the number and complexity of applications over the past five years prompted this review.   Additionally, new procedures in some overseas jurisdictions have been introduced to deal with cases where a miscarriage of justice may have occurred.  It is important for the maintenance of public confidence in the criminal justice system that the process for considering applications for the exercise of the Royal prerogative of mercy is just, cognisant of society’s changing socio-legal values, and efficient.

This paper provides a vehicle for discussion.  Its objective is to provide:

·           An overview of the law and practice in New Zealand

·           A review of overseas models

·           An overview of the issues the current processes in New Zealand gives rise to

·           Options and proposals for enhancing current practice


Comments on the issues and the proposals for improvements outlined in this paper are welcome.



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BACKGROUND


The nature of the Royal prerogative of mercy

The Royal prerogative of mercy is one of the prerogatives vested in the Queen as sovereign.  It operates in two different ways.  The first is the exercise of clemency either through the grant of a pardon or by ameliorating the penalty imposed by the court.  The second is to correct mistakes; to provide an acknowledgement that the judicial process with its reliance on rules of evidence and procedure, does not always reach the correct result as to guilt or innocence.  Notwithstanding appeal processes for convicted offenders, occasionally the judicial process is fallible.  Cases may arise where, after appeal rights have been exhausted, new evidence is discovered that tends to throw doubt on the correctness of the conviction.

In New Zealand the prerogative has been exercised by the Governor-General by virtue of a delegation in the Letters Patent Constituting the Office of Governor-General [100].   In terms of Article XI of the Letters Patent the Governor General is empowered to exercise the prerogative of mercy by:

·           Granting a free pardon (which has the effect of wiping the conviction and sentence)

·           Granting a pardon subject to conditions (substituting one form of punishment for another, leaving the conviction standing)

·           Granting respite of the execution of any sentence (a reduction without a change in the nature of the sentence)

·           Remitting the whole or part of any sentence, penalty or forfeiture

In addition, section 406 Crimes Act 1961 provides a statutory adjunct to the prerogative of mercy.  Since 1945, Parliament has empowered the Governor-General, when considering an application for exercise of the prerogative of mercy, to refer the question of the applicant’s conviction or sentence to the Court, or to seek the Court of Appeal’s assistance on any point arising in the case.   This referral process is intended to deal with possible miscarriages of justice.  In substance it reflects the pattern of legislation in other jurisdictions.

Most applications for the exercise of the prerogative in New Zealand seek relief under section 406 Crimes Act 1961.  Even in those cases where a pardon is sought, almost invariably the basis for the application is that a miscarriage of justice occurred.  The infrequency of applications for clemency no doubt reflects the availability of other processes.  These include the right to appeal against the sentence imposed in the trial court, and the ability for cases to be referred to the Parole Board for consideration for early release before a prisoner’s parole eligibility date.



Pardon – section 407 Crimes Act 1961

The grant of a pardon is the exercise of the prerogative of mercy to extend clemency.  By convention, it is exercised by the Governor-General on the advice of the Minister of Justice.  There have been few instances in New Zealand where either a free or conditional pardon has been granted. The case of Arthur Allan Thomas is the most well known. 

In terms of section 407 Crimes Act 1961, a convicted person who is granted a free pardon is deemed never to have committed the offence.   In contrast to the position in England, a pardon is not granted on the basis that the Executive accepts the convicted person committed the offence, but forgives him or her.  Nor can the convicted person ever again be charged with the offence in any court: Re Royal Commission on Thomas Case [1982] 1 NZLR 252(CA).  A pardon does not imply, however, that a person is necessarily innocent of the crime with which he or she was charged; it simply requires that for all legal purposes he or she is to be treated as if they were.

Applications for a conditional pardon are rare.  In some jurisdictions conditional pardons are granted to commute the death penalty to life imprisonment, or provide a pardon “in advance” to a person implicated in a crime on the condition the person provides assistance to the prosecution: see R v Milnes (1983) 33 SASR 211, 216.  The latter is facilitated in New Zealand by a Solicitor-General’s undertaking to stay any proceedings that might be commenced as a result of disclosures made, or by the issue of a stay of proceedings.[101] 



Miscarriages of justice - section 406 Crimes Act 1961

Though some applications for the exercise of the prerogative of mercy seek a pardon (see Burt v Governor-General [1992] 3 NZLR 672 (CA)), most applicants seek reference of their case to the Court of Appeal under section 406 Crimes Act 1961.  The most common basis for such a request is the existence of new evidence that discloses a miscarriage of justice has occurred.

Section 406 provides as follows:

Prerogative of mercy     Nothing in this Act shall affect the prerogative of mercy, but the Governor-General in Council, on the consideration of any application for the exercise of the mercy of the Crown having reference to the conviction of any person by any Court or to the sentence (other than a sentence fixed by law) passed on any person, may at any time if he thinks fit, whether or not that person has appealed or had the right to appeal against the conviction or sentence, either -

(a) Refer the question of the conviction or sentence to the Court of Appeal or, where the person was convicted or sentenced by a District Court acting in its summary jurisdiction or under section 28F(2) of the District Courts Act 1947, to the High Court, and the question so referred shall then be heard and determined by the Court to which it is referred as in the case of an appeal by that person against conviction or sentence or both, as the case may require; or

(b) If he desires the assistance of the Court of Appeal on any point arising in the case with a view to the determination of the application, refer that point to the Court of Appeal for its opinion thereon, and the Court shall consider the point so referred and furnish the Governor-General with its opinion thereon accordingly.


This provision allows the Governor-General in Council to either refer the applicant’s conviction or sentence to the Court where the reference is heard and determined as if it were an appeal, or to refer one or more points arising from the application to the Court of Appeal for its opinion.  The applicant need not have appealed against conviction or sentence, though it is usual for appeal rights to have been exhausted before an application for the prerogative is made.

A reference under section 406(a) leads to the Court hearing and determining the matters raised as if it were dealing with an appeal.  This results in the prerogative application being effectively determined by the Court.  In contrast, a reference under s 406(b) is designed to provide the Governor-General with the opinion of the Court on a point arising in the case.  The prerogative application, informed by that opinion, is then determined by the Governor-General acting on ministerial advice: R v Thomas [1978] 2 NZLR 1, 5 (PC).

Since 1963 the Court of Appeal has considered the scope of the section and the procedure to be followed on a number of occasions.  Some of the main points to emerge from the Court’s decisions can be summarised as follows:

·           The Court is assisted by being informed of the considerations that caused the Governor-General in Council to make the reference: R v Morgan [1963] NZLR 593 (CA); Collie v R [1997] 3 NZLR 653 (CA)

·           The Court will not re-adjudicate a ground of appeal that has already been heard and disposed of on the merits unless some new matter has come to light that makes a reconsideration of the ground necessary or desirable: R v Morgan [1963] NZLR 593 (CA); R v Ellis (1999) 17 CRNZ 411 (CA)

·           A second application for the exercise of the prerogative of mercy is not precluded: Ellis v R [1998] 3 NZLR 555 (CA)

·           The hearing and determination of a reference under s 406(a) is confined to the grounds specified in the reference.  The matters identified in effect become the points of appeal: Ellis v R [1998] 3 NZLR 555 (CA)

·           The fundamental inquiry is whether taken individually or collectively, the grounds of appeal demonstrate that there has been a miscarriage of justice, requiring the conviction to be set aside: R v Ellis  (1999) 17 CRNZ 411 (CA)

·           Where the reference requires the consideration of new evidence, an application to the Court for leave to adduce fresh evidence is required.  The practice regarding the reception of fresh evidence applies.  The normal rule that fresh evidence will not be received unless it is shown that such evidence is new or fresh in the sense that it was not available at trial, however, is not always applied rigidly if there is reason to think that to do so might lead to injustice or the appearance of injustice: Collie v R  [1997] 3 NZLR 653 (CA)

·           In determining whether there was a miscarriage of justice in the applicant’s conviction, the Court considers whether, had the fresh evidence been available at the trial, its cogency is such that it might reasonably have led the jury to return a different verdict:  R v Dougherty [1996] 3 NZLR 257 (CA)

·           The function of the Court is to decide the case on its true merits, but in doing so, in the overall interests of justice, it is required to apply established rules and principles: R v Ellis (1999) 17 CRNZ 411 (CA)

·           The opinion given by the Court to the Governor-General under a section 406(b)    reference is not reviewable: R v Thomas [1978] 2 NZLR 1 (PC)






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THE CURRENT PROCESS


How applications are considered



In accordance with constitutional conventions the Governor-General receives applications for the exercise of the prerogative of mercy in the first instance.   The Governor-General’s Private Secretary acknowledges receipt of the application, and advises the applicant that the matter will be referred to the Minister of Justice for advice. The papers are then referred by the Minister’s office to the Secretary for Justice for attention.

Once a Ministry legal adviser has considered the application (a process discussed below), a recommendation as to the outcome is forwarded to the Minister.  If the recommendation is that the application be declined, a draft letter addressed to the Governor-General’s Private Secretary setting out that advice and the reasons for it is considered by the Minister of Justice.  The advice to the Governor-General is accompanied by a letter to the applicant.  The Governor-General considers the advice, and if clarification of any issue is required the Minister’s Office attends to it.

If the Minister of Justice recommends either the granting of a pardon, or a referral to the Court under section 406 Crimes Act, the letter to the Governor-General’s Private Secretary containing the advice is accompanied by an Order in Council.  Upon notification to the Minister that the Governor-General has considered the advice and accepted it, the matter is formalised at a subsequent meeting of the Executive Council with the Governor-General signing the Order in Council.

The Private Secretary to the Governor-General advises the applicant (or his or her lawyer) of the outcome.



Threshold for considering applications

The exercise of the prerogative of mercy is not conducive to the rigid application of precisely defined criteria.  It is, however, appropriate for an identifiable threshold to be reached before miscarriage of justice applications can be considered.

When considering applications for a free pardon, the Ministry of Justice legal advisers consider first whether the applicant has exhausted all other remedies.  Secondly the advisers look for compelling evidence that the petitioner was not properly convicted, that no reasonable jury apprised of all the relevant evidence could have found the petitioner guilty.

Two principal criteria guide the process of considering applications for reference to the Court pursuant to section 406 Crimes Act 1961.   Firstly, the evidence raised by the application must be “fresh evidence” in the sense that it was not available at the time of trial, or, if not “fresh”, is otherwise of such a nature that it would give rise to grounds for an appeal.  Secondly, in addition, the evidence must be of sufficient weight and cogency that it is capable of pointing to a likely miscarriage of justice.

These two criteria are not applied rigidly as there is an overriding “interests of justice” consideration where a strict application of the principles might lead to an injustice or the appearance of injustice.  Instances where this has occurred can be found in the references under section 406(a) Crimes Act in R v Zachan, Court of Appeal, 11 August 1996, (CA 304/94) and Sims v R, Court of Appeal, 24 December 1997, (CA489/97).



Procedure within the Ministry of Justice

Legal advisers at the Ministry of Justice undertake the analysis and consideration of all applications for the exercise of the prerogative of mercy.  One of the Ministry’s senior managers is responsible for allocating, co-ordinating, and overseeing the process.

Each application is unique.  In some cases it is apparent at an early stage that the application does not reach the threshold for the prerogative of mercy to be exercised.  Some cases raise complex or numerous issues that can take months to work through.   Despite the differences from case to case, the process followed can be generally described.  

The Ministry’s legal adviser who reviews the application makes an initial assessment of the issues raised and what additional information is required.  Usually it will be necessary to obtain the relevant court file.  It is often necessary to seek further information from the applicant and occasionally the police investigation file will be sought.

If it becomes apparent that the application does not raise issues that could amount to a miscarriage of justice, a draft memorandum recommending the application be declined is prepared.  The case is further reviewed, usually by the Ministry’s Chief Legal Counsel, then submitted to the Minister of Justice for consideration together with a letter setting out the basis for the Minister’s advice to the Governor-General.

Some applications raise issues that cannot be resolved on the basis of the information available to the legal adviser reviewing the matter.  Further inquiry may be necessary or specialist advice sought.  In some cases it is appropriate to ask the Police to interview or reinterview a witness, or a report on forensic scientific issues is sought from Environmental Science and Research Ltd (ESR).  On occasion an independent barrister is retained to interview witnesses or to provide advice.  It is not uncommon for further information to be sought from or provided by the lawyer for the applicant.  Rarely do the Ministry’s legal advisers undertake inquiries themselves.

In the more complex cases more than one legal adviser may be asked to assist with reviewing an application.  Increasingly in these cases, a retired judge may also be requested to consider the application and provide a report, or review the Ministry’s analysis of the case. 

When the review of the application has been completed, the team member responsible for the review prepares a draft memorandum containing the recommendation to the Minister of Justice.  The recommendation and the memorandum are critically peer reviewed and then signed off by the Ministry’s Chief Legal Counsel before it is forwarded to the Minister’s Office.



Analysis of applications since 1996

Since 1996, 63 applications for the exercise of the prerogative of mercy have been received.  As at 30 June 2002, a decision had been made in respect of 47 applications.  Of those, 7 of the applications received resulted in a reference to the Court in terms of s 406 Crimes Act 1961, the terms of reference of an existing reference were widened in one case and a Ministerial inquiry held in another.  No pardons were granted and 38 applications were declined.  A general analysis of applications received since 1 January 1996 is outlined in the appendix.

As at 30 June 2002, 16 applications were under consideration, with ministerial advice yet to be tendered to the Governor-General.

In nearly half the cases a decision is made within three months from the time the application is received.  Some of the more recent applications, notably those in the Bain and Ellis cases, have taken much longer and involved issues of considerable complexity.

Counsel had assisted approximately 55% of applicants.




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JUDICIAL REVIEW


The extent to which the exercise of the prerogative of mercy is judicially reviewable has been the subject of numerous court decisions and articles by legal scholars.  For most of the twentieth century a long line of decisions of high authority held that the exercise of the prerogative of mercy was not reviewable in the courts essentially because the unique discretionary and extra legal nature of the power meant it was not amenable to the judicial process; see, for example, Horwitz v Connor (1908) 6 CLR 38 (HCA); Hanratty v Lord Butler of Saffron Walden (1971) 115 Sol J 386;  de Freitas v Benny [1976] AC 239 (PC); Reckley v Minister of Public Safety and Immigration No 2 [1996] 1 All ER 562 (PC).

With the developments in administrative law over the last 25 years, it has become accepted that the exercise of a prerogative power is not necessarily immune from judicial review.  The question of justiciability turns on whether the subject matter of the decision in question is amenable to review by the courts rather than the source or nature of the power that is being exercised.  This has led to decisions such as R v Secretary of State ex parte Bentley [1993] 4 All ER 442 where a Divisional Court held, in the exceptional circumstances of the case, that the Home Secretary had given insufficient consideration to the grant of a posthumous conditional pardon.  More recently the Privy Council departed from a line of its earlier decisions with respect to the review of the exercise of the prerogative of mercy in capital cases.   In Lewis v Attorney-General of Jamaica [2000] 3 WLR 1785, the Judicial Committee concluded that whilst the merits of the decision itself were not reviewable, the procedures by which the prerogative of mercy was exercised were justiciable.

Our Court of Appeal in Burt v Governor-General of New Zealand (1992) 8 CRNZ 499 had earlier recognised that in principle, there was no reason why the procedure followed in exercising the prerogative of mercy should not be open to judicial review.  In that case, however, it declined to take such a step.  The Court found that the Royal prerogative appeared to operate as an efficient safety net and when considered in the context of the other safeguards in the process, there was no pressing reason made out for altering the Court’s approach to the justiciability of the pardon power in that case. 

The Court in Burt was not called on to consider the situation with respect to a referral under section 406 Crimes Act 1961, but it is probable that the process is amenable to judicial scrutiny, at least with respect to the observance of the principles of administrative law.




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OVERSEAS MODELS


The above framework for considering applications for the Royal prerogative of mercy in New Zealand has, historically, been similar to that of England and other commonwealth countries.  In these jurisdictions the delegated or common law prerogative to pardon has also been supplemented by a statutory scheme providing for reference by the Executive to the Court to revisit a conviction or sentence, or to provide an opinion on an aspect of the case to the Executive.

To assist the consideration of possible improvement to the current process for considering cases where a miscarriage of justice may have occurred in New Zealand, the process in Australia, Canada, England, and Scotland were examined. Canada, England and Scotland have recently reviewed their processes, with the latter two making significant changes.


Australia

Applications for the exercise of the Royal prerogative of mercy are dealt with by State jurisdictions in Australia, and follow a broadly similar approach.[102]  The common law pardoning power, the exercise of which is delegated to State Governors, is supplemented by State legislation providing for reference of either a conviction or a sentence to the Court, usually by the Attorney-General.  If the whole case is referred it is determined as if it were an appeal.  Alternatively, any point arising from the case may be referred to the Court for its opinion.  The legislation and practice in Victoria illustrate the process.


Victoria

In Victoria, the provisions of section 584 of the Crimes Act 1958 follow the general pattern.  The Department of Justice receives approximately six to seven applications each year.  The cases fall into three categories, with applications alleging that a miscarriage of justice has occurred, seeking commutation of sentence, or raising “special circumstances” (that may also involve a miscarriage of justice).  In this latter group extra-judicial considerations may arise (such as inadmissible evidence), or wider contextual factors which suggest that there has been a miscarriage of justice, or that intervention is otherwise required.

A senior departmental lawyer assesses each case.  If there are no grounds for possible consideration, the application may be declined on advice from the Department.  If there is an arguable case, the application is referred to either the Government Solicitor, or occasionally, an independent lawyer for assessment and recommendation.  If there appears to have been a miscarriage of justice, the case will usually be referred to the Court under section 584(a) of the Crimes Act.

The majority of applications seek the commutation of sentence on compassionate grounds, as there is no statutory body to consider such cases.  In cases involving the possibility of a miscarriage of justice, independent inquiries are only rarely made.


New South Wales

New South Wales has an additional feature in its procedure for the review of convictions and sentences.  Since 1883, detailed provisions that were substantively amended in 1993 have supplemented the common law pardoning power.   In terms of Part 13A of the Crimes Act 1900 a review of a conviction or sentence can follow:

·           a petition to the Governor, who may direct an inquiry be held, or (through the Minister) refer the case to the Court of Criminal Appeal (section 474C); or

·           an application to the Supreme Court requesting the Court to order an inquiry, or to refer the matter to the Court of Criminal Appeal to be dealt with as an appeal (section 474E).


In each case, a direction or reference can only be made if it appears that there is a question as to the convicted person’s guilt, or to any mitigating circumstances in the case, or to any part of the evidence in the case.  The Governor, the Minister, or the Court may refuse to consider an application if the matter has been dealt with in the trial or appeal process, or previously considered under Part 13A, and if they are satisfied that there are no special facts or special circumstances that justify the taking of further action.

The procedure unique to New South Wales concerns the appointment of a judicial officer to conduct an inquiry with powers similar to a commission of inquiry.  The inquiry can also refer the question of whether the conviction should be quashed to the Court, if the inquiry is of the opinion that there is a reasonable doubt as to the guilt of the convicted person.


Canada

Canadian legislation relating to alleged miscarriage of justice cases followed the traditional pattern.  Section 690 of the Criminal Code empowered the Canadian Minister of Justice to refer the case of an applicant for the prerogative of mercy to a court of appeal for hearing, or refer a question to the court.  In addition, the Minister had the power to direct a new trial, an authority that in other jurisdictions was vested only in the Court.

In 1989, a Royal Commission recommended that provincial and federal Justice ministers consider creating an independent mechanism to facilitate the reinvestigation of alleged cases of wrongful conviction.  However, a working group established to examine the recommendation did not support the proposal and the ministers responsible for criminal justice took the proposal no further.

A Department of Justice Review in 1993 led to the establishment of the Criminal Conviction Review Group whose sole function was to investigate section 690 applications and report to the Minister of Justice.  Criticism of the section 690 process, however, later led to the Department of Justice publishing a consultation paper in 1998, “Addressing Miscarriages of Justice: Reform Possibilities for Section 690 of the Criminal Code”.  Options such as the English Criminal Cases Review Commission were discussed.  Following the consideration of submissions, the Minister of Justice considered a number of options.   The legislative response, which was passed in October 2001 as an amendment to the Criminal Code, repealed section 690 and inserted a new Part headed “Applications for Ministerial Review – Miscarriages of Justice”.

The three remedies provided by the repealed section remain, but for the purpose of any investigation relating to the application, however, the Minister, or the Minister’s delegate is vested with powers similar to those of a commission of inquiry.

In deciding whether to direct a new trial, or refer the case to a court of appeal for hearing and determination, the Minister must be “satisfied that there is a reasonable basis to conclude that a miscarriage of justice likely occurred.”[103]  In reaching that conclusion, the Minister is required to take account all relevant matters including:

·           Whether the application is supported by new matters of significance that were not considered by the courts

·           The relevance and reliability of information that is presented in connection with the application

·           The fact that the process is not a further appeal and any remedy is an extraordinary remedy [104]


Details of the process for reviewing applications are prescribed by regulations.

The number of applications for the prerogative of mercy in Canada varies between 50 and 70 a year.  There is also a separate process that results in the pardoning of people with historical convictions.  This process is the responsibility of the Canadian Parole Board, and leads to the expungement of the convictions of some 14,000 people a year.


England

For centuries in England the Royal prerogative of mercy was the sole means to remedy an injustice.  It was often used to ameliorate the harshness of sentences imposed by the Star Chamber in the 16th and 17th centuries.  It afforded clemency to those convicted of capital offences through the early 19th century when there were over 220 offences on the statute books carrying the death penalty.  In Queen Victoria’s reign responsibility for determining petitions devolved to the Home Secretary.

An appeal against conviction in criminal cases became an accused’s right in the early 20th century with the establishment of the Court of Criminal Appeal in 1907.  This was due to the highly visible miscarriages of justice that occurred in the Adolf Beck and George Edalji cases and others.[105]

Despite the availability of appellate review, the Home Office continued to handle hundreds of petitions for the exercise of the prerogative of mercy each year.  The Home Secretary had the power to refer cases to the Court, but there were concerns with the effectiveness of this process.  These focused on the process within the Home Office to consider applications and the narrow approach of the Court of Criminal Appeal to the exercise of its power to order a new trial.[106]  The Court’s approach prompted ATH Smith to comment, “The court’s own view of its constitutional role is that it exists to prevent error rather than to prevent injustice.”[107]

In 1968, the British Section of the International Commission of Jurists (“JUSTICE”) published a report [108] in which it recommended a number of improvements to the existing process that produced the advice to the Home Secretary.  JUSTICE considered alternatives, such as the Danish Court of Complaints, a special court, which operated outside the machinery of the ordinary appeal system to deal with miscarriages of justice.  However, it favoured a process of inquiry by an appointed commissioner or commissioners free from formal rules of evidence and procedure, with the commissioner reporting to the Home Secretary.

A series of highly publicised cases arising during the 1980’s in which a miscarriage of justice occurred coupled with concerns about the efficacy of the prerogative of mercy process led to the establishment of the Royal Commission on Criminal Justice (the Runciman Commission) in 1991.

In its report to Parliament in 1993 [109], the Commission recommended that the responsibility for reviewing allegations of a miscarriage of justice be removed from the Home Secretary and transferred to an independent authority to be established. 

The most significant consideration that led to this recommendation was the Commission’s conviction that existing arrangements were incompatible with constitutional principle.  It found that the role assigned to the Home Secretary under the 1968 Act to refer cases to the Court was inconsistent with the separation of powers as between the courts and the executive.  The “scrupulous” observance of constitutional principle led to a reluctance on the part of the Home Office to inquire deeply enough into the applications it received.

Effect was given to the Runciman Commission’s recommendation with the passage of the Criminal Appeal Act 1995.  This Act established the Criminal Cases Review Commission, an independent public body with 14 Commissioners and a staff of about 70.  It has an annual budget of around 5.5m pounds.

The statutory responsibilities of the Criminal Cases Review Commission are:

·           To review suspected miscarriages of justice

·           To refer a conviction, verdict, finding or sentence to the appropriate court of appeal when the Commission considers there is a real possibility it would not be upheld

·           To investigate and report to the Court of Appeal on any matter referred to the Commission by the Court

·           To consider and report to the Secretary of State on any matter referred to the Commission arising from consideration of whether or not to recommend the exercise of the prerogative of mercy in relation to a conviction


The Commission w