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PLEA BARGAINING
Milica Potrebic Piccinato
NOTES AND REFERENCES
1 |
Ontario Ministry of the Attorney General, Report
of the Attorney General’s Advisory Committee on Charge Screening,
Disclosure, and Resolution Discussions (generally referred
to as the "Martin Report", since the committee in question
was chaired by Mr. G. Arthur Martin), 1993, page 275. |
2 |
Law Reform Commission of Canada, Criminal Procedure : Control
of the Process (Working Paper No. 15), Ottawa, Information
Canada, 1975, page 45. |
3 |
An "included" offence is part of the main offence. The
main offence must contain the essential elements of the offence
said to be included (see Regina v. Beyo, Decision of the
Ontario Court of Appeal, [2000] Canadian Criminal Cases, Third Series,
volume 144, pages 15-35, at page 15, paragraph 29 (leave to Supreme
Court of Canada dismissed). The included offence must be a "lesser"
offence than the main offence. In other words, a lesser and included
offence is part of an offence that is charged, and it must necessarily
include some elements of the main offence but be lacking in some
of the essentials without which the main offence would be incomplete
(see Fergusson v. The Queen, Decision of the Supreme Court
of Canada, [1961] Canadian Criminal Cases, volume 132, pages 112-116,
at page 114.)
There are four ways in which an offence may be
included in another offence (see Regina v. Beyo, Decision
of the Ontario Court of Appeal, [2000] Canadian Criminal Cases,
Third Series, volume 144, pages 15-35) :
- A statute may expressly prescribe that a certain offence is
an included offence ; for example, section 662(3) of the Criminal
Code includes manslaughter or infanticide within the offence
of murder.
- The offence described in the enactment creating it includes
the commission of another offence ; for example, assault is a
lesser and included offence within the offence of assault causing
bodily harm created by section 267 of the Criminal Code.
- The description or wording of the offence charged in the charging
document may include the commission of another offence ; for example,
a count charging attempted murder may particularise the offence
of wounding.
- Section 660 of the Criminal Code provides that the
offence of attempt to commit the offence charged is an included
offence of the main offence charged.
Finally, section 606(4) of the Criminal Code
provides that an accused may plead not guilty to the offence charged
but guilty to any other offence arising out of the same transaction,
whether or not it is an included offence, with the consent of the
prosecutor. For example, a possible resolution discussion may involve
an accused agreeing to plead guilty to the lesser and included offence
of possession of a controlled substance but not guilty to the offence
charged of possession of a controlled substance for the purposes
of trafficking, which would carry a higher sanction (see section
5(2) of the Controlled Drugs and Substances Act, Statutes
of Canada, 1996, volume 1, chapter 19). |
4 |
Often an accused may be charged with a number
of related, similar or identical counts where, for example, the
criminal conduct transpires over a lengthy period of time, or the
impugned conduct has many criminal facets. In cases involving illegal
drug sales, a suspect may be charged with five counts of trafficking
of a controlled substance where the investigation discloses that
he sold illegal drugs over the course of a number of days to different
purchasers in different locations. A resolution agreement may involve
the accused pleading guilty to only one count of trafficking and
the prosecutor withdrawing the remaining four counts. In this case,
the accused would admit to trafficking over the course of five days
but only plead guilty to one "all-inclusive" count of
trafficking that would include the criminal conduct that transpired
over five days. Another example may involve an accused who is charged
with a number of offences, such as sexual assault, forcible confinement
and sexual exploitation, that arise out of one incident, pleading
guilty to the one "all-inclusive" count of sexual assault.
In this case, the prosecutor may withdraw the counts of forcible
confinement and sexual exploitation, if the accused admits to those
acts through the plea of guilty to the one count of sexual assault.
There is also the case of an accused engaging
in conduct that constitutes a "continuing offence". A
continuing or continuous offence is a concept well known in Canadian
criminal law and is often used to describe two different kinds of
crime. There is the crime that is constituted by conduct which goes
on from day to day and constitutes a separate and distinct offence
each day the conduct continues. There is, on the other hand, the
kind of conduct, generally of a passive character, that consists
in the failure to perform a duty imposed by law. Such passive conduct
may constitute a crime when first indulged in, but if the obligation
is continuous the breach — though constituting one crime only
— continues day by day to be a crime until the obligation
is performed (see Regina v. Rutherford [1990] Ontario Judgments
No. 136 (Ontario Court of Appeal), Quick Law citation). A resolution
agreement may include the prosecutor agreeing to prosecute the accused
for one count that encompasses a number of occurrences or acts taking
place over a period of time as one continuing offence or transaction.
For example, acts of theft occurring over a period of time involving
the same victim may be treated as one continuous offence and could
be covered in one single count of theft. See Regina v. Barnes,
Decision of the Nova Scotia Supreme Court (Appeal Division), [1975]
Canadian Criminal Cases, Second Series, volume 26, pages 112-127. |
5 |
The Ontario Court of Appeal in the decision
of Regina v. Garcia and Silva, [1970] Canadian Criminal
Cases, volume 3, pages 124-127 stated the following : "We agree
that frequently it is a sensible and proper thing for a Judge to
take into consideration other convictions and on occasions and under
proper safeguards other charges laid against a convicted person.
If other charges are taken into consideration, it seems to us those
safeguards should at least include the conditions that they are
charges with respect to which the accused will plead guilty or will
otherwise be proved guilty and that the Crown commits itself not
to proceed with those other charges in the event that they are taken
into consideration in sentencing on the conviction before the Court." |
6 |
In Canada there are two types of criminal
offences. The less serious criminal offences are classified as summary
conviction offences and are generally punishable by a maximum penalty
of a fine of $2,000 or six months imprisonment, or both (see section
787 of the Criminal Code). The most serious criminal offences
are classified as indictable offences and include offences such
as murder and robbery. Some criminal offences may be classified
as either summary conviction or indictable and are known as Hybrid
or Dual Procedure Offences. Examples of these offences include the
offences of theft, fraud and assault. The prosecutor is solely responsible
for electing whether to proceed by summary conviction or by indictment
when prosecuting a hybrid or dual procedure offence. Consequently,
this is an extremely important issue raised during resolution discussions,
as it has a serious impact on the potential criminal sanction. |
7 |
Under section 11(b) of the Canadian Charter
of Rights and Freedoms, Schedule B, Constitution Act, 1982,
chapter 11 (cited hereafter as Canadian Charter of Rights and
Freedoms) any person charged with an offence has the right
to be tried within a reasonable time. |
8 |
Pursuant to sections 478(3) and 479 of the
Criminal Code, a criminal charge once instituted by the
state can be transferred to another jurisdiction if the Attorney
General consents to the transfer and the accused pleads guilty to
the charge. This procedure does not apply to many serious offences
mentioned in section 469, including murder, treason, piracy, bribery
by a judicial officer and war crimes. |
9 |
Pursuant to section 732 of the Criminal
Code, an offender may serve a term of imprisonment of ninety
days or less on an intermittent basis. This form of sentence is
often imposed to permit the offender to continue employment and,
for example, will permit the offender to live at home during the
week and serve the sentence on weekends. |
10 |
A conditional sentence is a penal sanction
that is tantamount to a term of imprisonment ; however, the offender
is allowed, by operation of law, to serve the term of imprisonment
in the community. Pursuant to section 742.1 of the Criminal
Code, where a person is convicted of an offence and the court
imposes a sentence of imprisonment of less than two years and is
satisfied that serving the sentence in the community would not endanger
the safety of the community and would be consistent with the fundamental
principles of sentencing, the court may order that the offender
serve the sentence in the community, subject to the offender complying
with conditions of a conditional sentence order. |
11 |
Section 655 of the Criminal Code
provides that "where an accused is on trial for an indictable
offence, he or his counsel may admit any fact alleged against him
for the purpose of dispensing with proof thereof." |
12 |
In Canada, the burden rests on the prosecutor
to prove the voluntary nature of a statement made by an accused
beyond a reasonable doubt before it will be admitted into evidence
at trial. |
13 |
For example, section 8 of the Charter
of Rights and Freedoms states : "Everyone has the right
to be secure against unreasonable search or seizure." The burden
rests on the accused to establish on the balance of probabilities
or through a preponderance of the evidence that the state violated
this right. Part of this burden requires the accused to establish
that he has a reasonable expectation of privacy in the subject matter
of the search or seizure. (Edwards v. The Queen, Decision
of the Supreme Court of Canada, [1996] Canadian Criminal Cases,
Third Series, volume 104, pages 136-160. The prosecutor may agree
to dispense with the accused’s requirement to establish his
reasonable expectation of privacy in a case where it is absolutely
clear that the accused did have such an expectation when the state
conducted a search or seizure, such as the search of the accused’s
dwelling house. |
14 |
This definition is found in D.W. Perras, "Plea
Negotiations", The Criminal Law Quarterly, volume
22, 1979-1980, pages 58–73, at pages 58-59, and was accepted
as an apt definition in the Martin Report. It must be noted that
there is no formal definition of the concept of plea bargaining
in the Criminal Code (Revised Statutes of Canada, 1985,
chapter C-46). |
15 |
Law Reform Commission of Canada, Plea
Discussions and Agreements (Working Paper 60), Ottawa, 1989,
page 5. |
16 |
"Should We Really "Ban" Plea
Bargaining? : The Core Concerns of Plea Bargaining Critics",
Emory Law Journal, volume 37, pages 753–783, at page
768. |
17 |
Law Reform Commission of Canada, Plea
Discussions and Agreements (Working Paper 60), Ottawa,1989,
page 6. |
18 |
Sections 606(1) and 607(1) of the Criminal
Code states that an accused who is called on to plead may plead
guilty or not guilty, or the special pleas of autrefois acquit,
autrefois convict and pardon, and no others. |
19 |
Section 10(b) of the Charter of Rights
and Freedoms provides that : "Everyone has the right on
arrest or detention to retain and instruct counsel without delay
and to be informed of that right". |
20 |
The Law Society of Upper Canada, Rules
of Professional Conduct, Rule 4.01, "The Lawyer as Advocate",
Commentary on Rule 4.01(1).
Available at http://www.lsuc.on.ca/regulation/a/profconduct/rule4/ |
21 |
The Law Society of Upper Canada, Rules of Professional
Conduct, Rule 4.01(9)(c) and (d) (available at http://www.lsuc.on.ca/regulation/a/profconduct/rule4/)
state that the lawyer may enter into an agreement with the prosecutor
about a guilty plea only where the client voluntarily is prepared
to admit the necessary factual and mental elements of the offence
charged ; and the client voluntarily instructs the lawyer to enter
into an agreement as to a guilty plea. |
22 |
"Should We Really "Ban" Plea
Bargaining? : The Core Concerns of Plea Bargaining Critics",
Emory Law Journal, volume 37, pages 753-783, at page 771. |
23 |
Dianne L. Martin, "Mandatory Minimum
Sentences : Law and Policy", Osgoode Hall Law Journal,
volume 39, 2001, pages 513-527, at paragraphs 8 and 23. |
24 |
In the Supreme Court of Canada’s decision
of Lavallee v. The Queen, Decision of the Supreme Court
of Canada, [1990] Canadian Criminal Cases, Third Series, volume
55, pages 97-133, the accused shot her husband in the back of the
head as he left the room. Evidence at trial established that the
accused had been repeatedly physically abused by her husband and
that he told the accused that he was going to kill her. The accused
wife successfully raised the defence of self-defence and was acquitted.
The Court held that expert testimony regarding the "battered-wife
syndrome" was admissible and relevant and necessary in respect
of the issues of the accused’s mental state and elements of
the defence of self-defence. |
25 |
The Honourable Justice Lynn Ratushny, Self
Defence Review : Final Report submitted to the Minister of Justice
of Canada and to the Solicitor General of Canada, Ottawa, 11
July 1997.
Available at http://canada.justice.gc.ca/en/dept/pub/sdr/rtush.html |
26 |
More precisely : $58.91 billion (Canadian
dollars)
Department of Justice of Canada, Research and Statistics Division,
JustStats (No.2002-01), October 2002. |
27 |
Protection costs are estimated to be 13% of
the total cost of crime or $7.49 billion (Canadian dollars). They
include expenditures on security and insurance administration. |
28 |
Victim costs are 67% of the total cost of
crime or $39.44 billion. These costs include property that is stolen
or damaged, emotional and physical impact on victims, lost output,
health services, victim support services and drug-related costs. |
29 |
More exactly : $11.97 billion.
Department of Justice of Canada, Research and Statistics Division,
JustStats (No.2002-01), October 2002. |
30 |
The 91.3% figure includes all charges that
are resolved by guilty pleas or withdrawn by the prosecutor. (See
The Commission on Proceedings Involving Guy Paul Morin, Testimony
of Peter Griffiths relating to Exhibit 292, Statistical Monitoring
Report of Ontario Court, Provincial Division,12 December 1997,
available on Quick Law in database "CRCM".) Of the 91.3%
of cases, 75.5% were resolved before trial, while the other 15.8%
remained unresolved until the day set for trial. (See The Investment
Strategy Report, Ontario Ministry of the Attorney General, Third
Quarter of 1998, referred to in the Report of the Criminal Justice
Review Committee, February 1999, Chapter 6, Part 4, available
on Quick Law in database "CRCM".) |
31 |
Ontario Ministry of the Attorney General,
Report of the Attorney General’s Advisory Committee on
Charge Screening, Disclosure, and Resolution Discussions, 1993,
pages 1-523, at page 277. |
32 |
The Law Society of Upper Canada, Rules
of Professional Conduct, Rule 4.01(9).
Available at http://www.lsuc.on.ca/regulation/a/profconduct/rule4/ |
33 |
Re Skogman and The Queen, Decision of the Supreme Court
of Canada, [1984] Canadian Criminal Cases, Third Series, volume
13, pages 161-185. |
34 |
Regina v. Power, Decision of the
Supreme Court of Canada, [1994] Canadian Criminal Cases, Third Series,
volume 89, pages 1-39. |
35 |
Canada, Department of Justice, Federal
Prosecution Service Deskbook, "Proceedings at Trial and
on Appeal", Chapter 20, pages V-20-1 to V-20-11, at page V-20-1.
Available at http://www.canada.justice.gc.ca/en/dept/pub/fpsdeskbook.pdf
|
36 |
Federal Prosecution Service Deskbook,
"Proceedings at Trial and on Appeal", Chapter 20, pages
V-20-1 to V-20-11, at page V-20-5. |
37 |
Federal Prosecution Service Deskbook,
"Proceedings at Trial and on Appeal", Chapter 20, pages
V-20-1 to V-20-11, at page V-20-8. |
38 |
"Should We Really "Ban" Plea
Bargaining? : The Core Concerns of Plea Bargaining Critics",
Emory Law Journal, volume 47, 1998, pages 753–783,
at page 765. |
39 |
The duty on the prosecutor is triggered by a request from the
defence. There is, therefore, an obligation on defence counsel to
request disclosure from the prosecution. See Stinchcombe v.
The Queen, Decision of the Supreme Court of Canada, [1992]
Canadian Criminal Cases, Third Series, volume 68, pages 1-18. In
cases where the accused is not represented by counsel, the prosecutor
is obligated to arrange to have the accused informed of the right
to disclosure and that disclosure is available, and to determine
how disclosure can best be provided to the accused. (See also Federal
Prosecution Service Deskbook, "Proceedings at Trial and
on Appeal", Chapter 18, pages V-18-1 to V-18-22, at pages V-18-15
to V-18-17). |
40 |
Stinchcombe v. The Queen, Decision
of the Supreme Court of Canada, [1992] Canadian Criminal Cases,
Third Series, volume 68, pages 1-18. |
41 |
Federal Prosecution Service Deskbook,
"Proceedings at Trial and on Appeal", Chapter 18, pages
V-18-1 to V-18-22, at page V-18-2. |
42 |
Federal Prosecution Service Deskbook,
"Proceedings at Trial and on Appeal", Chapter 20, pages
V-20-1 to V-20-11, at page V-20-2. |
43 |
Lamoureux v. Regina, Decision of
the Quebec Court of Appeal, [1984] Criminal Reports, Third Series,
volume 40, pages 369-375, at page 373. |
44 |
Regina v. S.K., Decision of the Ontario
Court of Appeal, [1995] Canadian Criminal Cases, Third Series, volume
99, pages 376–383, at pages 381–382. |
45 |
Regina v. S.K., Decision of the Ontario
Court of Appeal, [1995] Canadian Criminal Cases, Third Series, volume
99, pages 376–383, at pages 381–382. |
46 |
Regina v. Layte, Decision of the
Ontario County Court, [1984] Criminal Reports, Third Series, volume
38, pages 204–208, at page 208. |
47 |
Regina v. Cerasuolo, Decision of
the Ontario Court of Appeal, [2001] Canadian Criminal Cases, Third
Series, volume 151, pages 445-448, at page 447. |
48 |
Regina v. Dorsey, Decision of the
Ontario Court of Appeal, [1999] Ontario Appeal Cases, volume 123,
pages 342-346, at page 345. |
49 |
Regina v. Cerasuolo, Decision of
the Ontario Court of Appeal, [2001] Canadian Criminal Cases, Third
Series, volume 151, pages 445-448, at page 447. |
50 |
Ontario Ministry of the Attorney General,
Report of the Attorney General’s Advisory Committee on
Charge Screening, Disclosure, and Resolution Discussions, 1993,
page 279. |
51 |
Regina v. Rubenstein, Decision of
the Ontario Court of Appeal, [1988] Canadian Criminal Cases, Third
Series, volume 41, pages 91-95, at pages 94-95, leave to appeal
to Supreme Court of Canada refused, [1988] Canadian Criminal Cases,
Third Series, volume 41, page VI. |
52 |
In Canada, the principle of stare decisis
or common law precedents are adhered to. These concepts involve
a doctrine that, when a court has once laid down a principle of
law as applicable to a certain state of facts, it will adhere to
that principle and apply it to all future cases, where the facts
are substantially the same, regardless of whether the parties and
property are the same. Once a decision is made by a court, it is
an authority or a binding precedent in the same court or in other
courts of equal or lower rank in subsequent cases where the very
point is again in controversy. (See Black’s Law Dictionary,
6th Edition, West Publishing Co., 1990). |
53 |
Ontario Ministry of the Attorney General,
Report of the Attorney General’s Advisory Committee on
Charge Screening, Disclosure, and Resolution Discussions, 1993,
page 289. |
54 |
Ontario Ministry of the Attorney General,
Report of the Attorney General’s Advisory Committee on
Charge Screening, Disclosure, and Resolution Discussions, 1993,
page 289. |
55 |
Ontario Ministry of the Attorney General,
Report of the Attorney General’s Advisory Committee on
Charge Screening, Disclosure, and Resolution Discussions, 1993,
page 316. |
56 |
The Honourable Patrick T. Galligan, Report
to the Attorney General of Ontario on Certain Matters Relating to
Karla Homolka, 15 March 1996, page 98. |
57 |
In certain circumstances, it may be necessary
to discuss some aspects of a resolution agreement with the trial
judge privately. This should be done only in rare and compelling
situations involving facts that, in the interest of the public or
the accused, ought not to be disclosed publicly. Common examples
include cases where the accused is terminally ill or has acted as
a confidential informer for the police. |
58 |
Federal Prosecution Service Deskbook,
"Proceedings at Trial and on Appeal", Chapter 20, pages
V-20-1 to V-20-11, at page V-20-10. |
59 |
Ontario Court of Justice Criminal Proceedings
Rules, Rule 28.03(1).
Available at http://laws.justice.gc.ca/en/C-46/SI-92-99/82202.html |
60 |
Section 625.1 of the Criminal Code. |
61 |
Section 625.1(2) of the Criminal Code. |
62 |
Ontario Ministry of the Attorney General,
Report of the Attorney General’s Advisory Committee on
Charge Screening, Disclosure, and Resolution Discussions, 1993,
page 365. |
63 |
Ontario Ministry of the Attorney General,
Report of the Attorney General’s Advisory Committee on
Charge Screening, Disclosure, and Resolution Discussions, 1993,
page 366. (See also Regina v. Atkinson, Decision of the
English Court of Appeal, [1978] Criminal Appeal Reports, volume
67, pages 200-203, at page 202). |
64 |
Ontario Ministry of the Attorney General,
Report of the Attorney General’s Advisory Committee on
Charge Screening, Disclosure, and Resolution Discussions, 1993,
page 367. |
65 |
Ontario Ministry of the Attorney General,
Report of the Attorney General’s Advisory Committee on
Charge Screening, Disclosure, and Resolution Discussions, 1993,
page 368. |
66 |
Boucher v. The Queen, Decision of
the Supreme Court of Canada, Canadian Criminal Cases, volume 110,
pages 263-280, at page 270. |
67 |
Federal Prosecution Service Deskbook,
"Principles Governing Crown Counsel’s Conduct",
Chapter 9, pages III-9-1 to III-9-14, at page III-9-5. |
68 |
Ontario Ministry of the Attorney General,
Report of the Attorney General’s Advisory Committee on
Charge Screening, Disclosure, and Resolution Discussions, 1993,
page 313. |
69 |
Ontario Ministry of the Attorney General,
Report of the Attorney General’s Advisory Committee on
Charge Screening, Disclosure, and Resolution Discussions, 1993,
page 313. |
70 |
Regina v. Agozzino, Decision of the
Ontario Court of Appeal, [1970] Canadian Criminal Cases, volume
1, pages 380-382, at page 381 ; Regina v. Brown, Decision
of the Ontario Court of Appeal, [1972] Canadian Criminal Cases,
Second Series, pages 227-228, at page 228. |
71 |
Attorney General of Canada v. Roy,
Decision of Quebec Queen’s Bench, [1972] Criminal Reports
New Series, volume 18, pages 89-93 at page 93 ; also cited in Federal
Prosecution Service Deskbook, "Proceedings at Trial and
on Appeal", Chapter 20, pages V-20-1 to V-20-11, at page V-20-11,
and Law Reform Commission of Canada, Plea Discussions and Agreements
(Working Paper 60) (Ottawa : 1989), page 30. |
72 |
Bernardo Investigation Review : Report
of Mr. Justice Archie Campbell, June 1996, page 1. |
73 |
The Honourable Patrick T. Galligan, Report
to the Attorney General of Ontario on Certain Matters Relating to
Karla Homolka, 15 March 1996, page 231. |
74 |
The Honourable Patrick T. Galligan, Report
to the Attorney General of Ontario on Certain Matters Relating to
Karla Homolka, 15 March 1996, pages 55–64, 71–76,
84–89, 232. |
75 |
The Honourable Patrick T. Galligan, Report
to the Attorney General of Ontario on Certain Matters Relating to
Karla Homolka, 15 March 1996, page 89. |
76 |
The Honourable Patrick T. Galligan, Report
to the Attorney General of Ontario on Certain Matters Relating to
Karla Homolka, 15 March 1996, pages 90–93. |
77 |
The Honourable Patrick T. Galligan, Report
to the Attorney General of Ontario on Certain Matters Relating to
Karla Homolka, 15 March 1996, pages 97–109. |
78 |
The Honourable Patrick T. Galligan, Report
to the Attorney General of Ontario on Certain Matters Relating to
Karla Homolka, 15 March 1996, pages 46, 50. |
79 |
The Honourable Patrick T. Galligan, Report
to the Attorney General of Ontario on Certain Matters Relating to
Karla Homolka, 15 March 1996, pages 46, 193. |
80 |
The Honourable Patrick T. Galligan, Report
to the Attorney General of Ontario on Certain Matters Relating to
Karla Homolka, 15 March 1996, page 89. |
81 |
The Honourable Patrick T. Galligan, Report
to the Attorney General of Ontario on Certain Matters Relating to
Karla Homolka, 15 March 1996, page 51. |
82 |
The Honourable Patrick T. Galligan, Report
to the Attorney General of Ontario on Certain Matters Relating to
Karla Homolka, 15 March 1996, page 51. |
83 |
The Honourable Patrick T. Galligan, Report
to the Attorney General of Ontario on Certain Matters Relating to
Karla Homolka, 15 March 1996, pages 2, 7. |
84 |
The Honourable Patrick T. Galligan, Report
to the Attorney General of Ontario on Certain Matters Relating to
Karla Homolka, 15 March 1996, page 111. |
85 |
The Honourable Patrick T. Galligan, Report
to the Attorney General of Ontario on Certain Matters Relating to
Karla Homolka, 15 March 1996, pages 112–113. |
86 |
The Honourable Patrick T. Galligan, Report
to the Attorney General of Ontario on Certain Matters Relating to
Karla Homolka, 15 March 1996, pages 192, 201, 203–204. |
87 |
The Honourable Patrick T. Galligan, Report
to the Attorney General of Ontario on Certain Matters Relating to
Karla Homolka, 15 March 1996, page 201. |
88 |
Section 610(2) of the Criminal Code
states that a conviction for the offence of manslaughter bars a
subsequent indictment for the same homicide charging it as murder. |
89 |
The Honourable Patrick T. Galligan, Report to the Attorney
General of Ontario on Certain Matters Relating to Karla Homolka,
15 March 1996, page 201. |
90 |
The Honourable Patrick T. Galligan, Report to the Attorney
General of Ontario on Certain Matters Relating to Karla Homolka,
15 March 1996, page 199. |
91 |
The Honourable Patrick T. Galligan, Report to the Attorney
General of Ontario on Certain Matters Relating to Karla Homolka,
15 March 1996, page 197. |
92 |
The Honourable Patrick T. Galligan, Report to the Attorney
General of Ontario on Certain Matters Relating to Karla Homolka,
15 March 1996, page 203. |
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