Inclusive Juries—Access for People Who Are Deaf, Hard of Hearing, Blind or Have Low Vision: Report (html)
16. Excuse from jury service
Only the range of excuses that apply to the general community should apply if the law is changed to better assist people who are blind or with low vision to serve. If we want to be regarded as equal citizens, then we should uphold our civic responsibilities.[1]—Participant in the Blind Citizens Australia consultation
Overview
• People in the subject groups should be able to be excused from jury duty for reasons connected to their disability. The Juries Act 2000 (Vic) (the Act) provides enough scope for this to occur. The Commission does not recommend including disability, in and of itself, as a ground for an excuse.
• In keeping with current practices, the excuse process should not be overly burdensome. To allay concerns about serving as a juror, Juries Victoria should provide information explaining the excuse process.
• Data should be retained about how often, at what stage and the reasons why a person from the subject groups applies to be excused. This should include information about adjustments that are unsatisfactory to a person in the subject groups.
• We recommend that section 32(3) of the Act is amended to make it clear that the court can excuse a panel member on its own motion pursuant to that section.
When should a person be able to be excused?
16.1 Sometimes a person from the subject groups may not feel comfortable serving on a jury, even with reasonable adjustments. This chapter considers how and when people from the subject groups should be able to be excused from serving on a jury.
16.2 Based on the recommendations in this report, people in the subject groups will be excluded from jury duty only if:
• a judge decides that reasonable adjustments cannot be provided, or
• where the person is excused, or
• otherwise ordered by the court.
16.3 With regard to being excused, two approaches could be taken:
1) provide a specific exemption in the Act ‘as of right’, which would mean that a person could be excused simply because they have a disability, or
2) allow people from the subject groups to be excused in the same way and on the same grounds as every other juror, on a case-by-case basis for ‘good reason’.[2]
When can a person currently seek to be excused?
16.4 The Act provides various reasons for excuse from jury service. Some of these require the potential juror themselves to seek to be excused; others are instigated by application by the Juries Commissioner or ordered by the court.
16.5 Section 8(1) allows a person to ask the Juries Commissioner to be excused at any time before becoming a member of a panel. The Juries Commissioner may excuse a person if ‘satisfied that there is good reason for doing so’.[3] Examples of ‘good reason’ provided in the Act, include:
• illness or poor health
• incapacity
• substantial hardship to the person
• advanced age
• any other matter of special urgency or importance.[4]
16.6 A person (or someone on their behalf) may also apply to the Juries Commissioner to be permanently excused from jury service. The Juries Commissioner may do so if satisfied that there is ‘good reason’ which includes:
• continuing poor health
• disability
• advanced age.[5]
16.7 The Juries Commissioner may also defer service if a person wishes to do so before they join a panel.[6]
16.8 The court may excuse a person from jury duty on application from the Juries Commissioner if the court is satisfied that there is a ‘good reason’ for doing so or order that a person not perform jury service if it is ‘just and reasonable to do so.’[7] The judge may also excuse people late in the selection process after informing the panel about the trial (discussed below).[8] In this situation, the excused person must return to the jury pool, unless the court otherwise orders, and may be selected for a different jury panel.[9]
Excuses from jury service in other jurisdictions
16.9 Other jurisdictions address in varied ways the question of when and how people with disabilities should be able to ask to be excused.
Australian Capital Territory
16.10 In the Australian Capital Territory (ACT) the Juries Act 1967 (ACT) creates a positive obligation on the court to consider the provision and assessment of reasonable supports. There is no specific exemption or excuse ‘as of right’ for people with disabilities. However, a person ‘may claim an exemption from serving as a juror’.[10] The Juries Regulation 2018 prescribes categories of people who may qualify for exemption, such as ‘a person with disability’, including ‘a person who is totally or partially blind, or totally or partially deaf’.[11]
16.11 A general excuse provision in the ACT Juries Act states that ‘if a judge or the sheriff is satisfied that a person summoned or appointed to attend to serve as a juror has shown sufficient reason to be excused’,[12] then ‘the judge or the sheriff may, at any time after service of the summons or the appointment, excuse the person from attendance or further attendance’.[13] Examples of ‘sufficient reasons’ include pregnancy, illness and where ‘the person has care of children or of aged or ill people’.[14]
England and Wales
16.12 In England and Wales, reasonable accommodations are provided where possible, subject to the requirements of the 13th person rule.[15]
16.13 The Juries Act 1974 (UK), which applies to England and Wales, states that a summons for a person with a disability should only be discharged if the person is incapable of acting effectively as a juror.[16] There is no excuse ‘as of right’ for people with disabilities. Rather, this legislation provides a general discretion to exclude a person for good reasons if a person can demonstrate:
to the satisfaction of the appropriate officer that there is good reason why [they] should be excused from attending in pursuance of the summons, the appropriate officer may excuse [them] from so attending.[17]
Monroe County, New York State, United States
16.14 The basis for the excuse is on medical grounds in Monroe County, New York State. There is no legislative provision specifically pertaining to disability because the Americans with Disabilities Act requires that the court provides access for people with disabilities.
16.15 The Jury Commissioner’s approach is that if a person receives a disability pension, no further proof of disability is required; in those circumstances, a permanent medical excuse from service is available. For example, if a person notifies the Jury Commissioner that hearing support would not assist them to serve, the Jury Commissioner may excuse the person indefinitely.[18]
16.16 The Jury Commissioner told us that ‘most people who are medically disabled ask to be excused from service’. The Jury Commissioner ‘very rarely needs to split hairs about whether a person should serve or not’.[19]
New Zealand
16.17 We were told by consultees from the High Court and District Court of New Zealand that, of the thousands of summonses sent out over the past three years, only 14 people have been excused for reasons of disability from the High Court and only one from the District Court. The consultees further noted:
There seems to be quite a bit of self-selection when it comes to potential jurors with hearing or vision loss. Some people contact the court after they have received their summons (usually around six weeks prior to the trial) to say, ‘I have disability x, what does the court have to support me to serve?’. However, more commonly, a person with hearing or vision loss will call and state that ‘I have reflected on it, and learned about the system, and don’t feel comfortable to serve’.[20]
16.18 A New Zealand court consultee noted that excuse is currently dealt with on a case-by-case basis. If a person with disability is willing to serve, the court works with them to facilitate it. However, it was also noted that excusal should be an option for those with disabilities.[21]
What did other law reform bodies say about excuse from jury service?
16.19 Previous reviews by law reform bodies have emphasised the importance of making a case-by-case assessment of the provision of reasonable adjustments. There was a preference for excuse ‘for good cause’ rather than ‘as of right’.[22] For example, the New South Wales Law Reform Commission (NSWLRC) recommended that:
Sickness, infirmity or disability which renders a person unable to discharge the duties of a juror should no longer be a ground of exclusion, but should be considered as a ground of excusal for good cause.[23]
16.20 The NSWLRC explained that:
The preferable course is to treat it, on a case by case basis, as a potential ground for excuse for good cause, reserving to the authority that administers the Act the capacity to grant either a permanent excusal, or an excusal for a particular trial.[24]
16.21 The Queensland Law Reform Commission recommended that considerations around excusal for cause should be made by reference to guidelines, which should:
include information for prospective jurors with physical disabilities about the facilities that may be available, and the procedures that should be followed, to enable them to serve. There may also be benefit in providing guidance for the Sheriff, and the Court, in assessing whether a person’s physical disability can be accommodated … The Commission does not anticipate, however, that the guidelines would be overly prescriptive; it is necessary to maintain the discretion and flexibility to consider and deal with individual circumstances.[25]
Community responses: excuse from jury service
16.22 In response to this inquiry, advocacy groups and other consultation participants held a range of views. The difference between excuse as of right and for good cause is nuanced and complex, with some responses revealing that perhaps this distinction was not well understood. Overall, however, there was a consensus that people in the subject groups may sometimes need to be excused because of issues relating to disability, despite being otherwise eligible to serve with reasonable adjustments.
Advocacy groups
16.23 Most advocacy groups supported the idea that disability should not be an excuse in and of itself. However, they thought that people in the subject groups should still be able to seek to be excused if they felt that they could not perform the role of juror due to the impact of their disability. The same conclusion was reached in the campaign for equal participation for women on juries in the 1960s and 1970s. We discussed this in Chapter 5.
16.24 The Victorian Equal Opportunity and Human Rights Commission commented in consultation that:
Not creating a system of low expectations is important. The starting point is that all people have civic rights and duties to take part in public life, including the jury system.[26]
16.25 Vision Australia was of the view that blindness or low vision should, in general, not be a sufficient reason for being excused from jury service. It explained:
However, there may be reasons associated with an individual’s disability that make it difficult or impossible for them to serve, and it should not be unduly onerous for them to seek to be excused in such cases. For example, a person who is blind may not have access to the technology needed to read electronic documents, or they may lack specific skills in reading the complex documents that will form evidence in a particular trial. A person may also have additional disabilities that will make it more difficult for them to participate effectively in the jury process. It is therefore important that the Act include clear guidance and enumeration of reasons that would be sufficient for an excuse. It is also important that there is the option for an excuse to be limited to a particular case, rather than automatically triggering a permanent exemption.[27]
16.26 In consultation, Youth Disability Advocacy Service (YDAS) explained its view that there should continue to be an option for people to be excused on the basis of disability, but that this should not be framed as the ‘primary reason for allowing people to be excused’ because this might reinforce assumptions about the abilities of people from the subject groups and provide an excuse for the courts not to provide adjustments. Instead, YDAS suggested that ‘Consideration of the person’s disability should be included as a background/contributing factor for other reasons why they may need to be excused’.[28]
16.27 The 2007 Blind Citizens Australia Position Statement on Jury Service sets out its view on when excuse should be available:
Legislation should require that only after support services provided to perform jury service are considered, can difficulty with performing jury duties on the basis of blindness or vision impairment be grounds for being excused from jury service on the basis of the blindness or vision impairment.[29]
Responses by people from the subject groups
16.28 The majority of people from the subject groups who were involved in consultations, surveys or who contributed submissions believed that excuse from jury service should only be available as it is for all community members. For example, Alastair McEwin expressed the view that reforms should not allow ‘special exceptions’ for people in the subject groups but focus on ‘core principles of equality’ and what adjustments are required for a person from the subject group to serve: ‘People should not be allowed to be excused on the basis of deafness alone’.[30]
16.29 Brent Phillips shared his strong view that a deaf person should not use their deafness as an excuse not to serve. He explained: ‘Deaf people have to work hard to get access and should exercise their civic duty once they are able to do so’.[31]
16.30 A number of survey respondents also suggested that excuse should occur on the same basis as the rest of the community.[32] For example, a survey respondent who identified as blind said:
A blind person should only be excused on the same basis as everyone else. Given the disproportionate outcomes Victorians with a disability experience in our justice system and the systemic discrimination experienced by many disabled lawyers seeking judicial appointment, it is imperative that more disabled Victorians step up to jury service.[33]
Wariness about participating as jurors
16.31 While not supporting disability as an excuse by itself, some responses noted that people in the subject groups may lack the confidence to participate as jurors.
Alastair McEwin explained:
However, it must also be remembered that deaf people might not feel confident to do jury duty. Until there is cultural change deaf people will continue to expect less from themselves. … [as far as I know] there are no deaf role models in Australia of anyone who has served on a jury. Therefore, it will be important for deaf people to see other deaf people doing these roles.[34]
16.32 Deaf Victoria consultation participants commented on the importance of empowering deaf people:
Often deaf people may feel that it’s not important for them to be involved, because they have been systematically undervalued and may feel a sense of lack of ownership of the process. Therefore, creating an environment where they feel responsibility for being involved is important.
Many deaf people are made to feel that they must rely on others to do things. Empowering deaf people is vital. Being deaf should not be used as an excuse to get out of jury duty.[35]
16.33 Some responses emphasised the importance of letting the person with a disability identify what they can and cannot do.[36] One survey respondent commented:
I think that blind people should be able to excuse themselves from particular cases as they will be best placed to know their ability in terms of being able to assess the evidence accurately.[37]
16.34 However, others maintained that disability should be a ground for excuse and that flexibility is needed. For example, one survey respondent explained:
I do think that disability is a reasonable ground for jury exemption. Despite the ability of many disabled people to serve on the jury in many different cases, I think it would be unfair to deny them the choice of opting out. Many people with disabilities have additional responsibilities or circumstances which might make jury service laborious, and as such, I think that they should be given the choice on whether they believe jury service is tenable for them.[38]
Legal representatives
16.35 Legal bodies (namely the courts, Juries Victoria, the Office of Public Prosecutions (OPP), the Law Institute of Victoria (LIV), and Victoria Legal Aid (VLA)) made it clear that they did not think that people should be required to serve if they did not feel comfortable serving. Making it hard for people to be excused would make things difficult for the trial judge and for the running of the trial.
16.36 Juries Victoria submitted that no change to the existing legislation is necessary:
JV supports maintaining the option for a person within the subject groups to request to be excused or permanently excused from jury service based on their impairments. This requires no change to current legislation, as these options already exist under section 8 and 9 of the Act, respectively.[39]
16.37 In submissions and consultations VLA, the LIV and the OPP stressed the importance of maintaining an option of being excused. The OPP highlighted the importance of affording choice to people from the subject groups about whether or not to serve with adjustments.[40]
16.38 Similarly, the County Court submitted that it considers:
it is important for prospective jurors in the subject group to be excused due to their hearing or vision loss, if they wish. This would be similar to the situation for jurors over a certain age or with primary carer responsibilities.[41]
16.39 The Supreme Court did not offer a view on this specific policy issue, but observed more broadly that:
In hearing excuses the Court considers the importance of a representative jury and the need to ensure a fair trial. Mere inconvenience to an individual is not sufficient reason to excuse. It is however appropriate to consider the extent to which the particular imposition on the individual would impact on their concentration and the discharge of their duty. Some weight must attach to an individual’s own assessment of their capabilities, whether that be in their assessment of their capacity to bring an open mind to the case because of a particular experience, or their capacity to engage in all aspects of the jury process with supports.
At whatever stage of the process an individual seeks to be excused there are options to maintain a level of privacy. If the person seeks to be excused on account of their disability but does not wish to reveal the reason in open court, they may write their excuse on a piece of paper after having sworn an oath or made an affirmation.[42]
Reasons why a person with disability might want to be excused
16.40 The following examples were suggested to the Commission as possible reasons why a person from the subject groups may seek to be excused:
• A person has not yet come to terms with recent onset vision or hearing loss.
• A person feels apprehensive about being involved in an unfamiliar process.
• One Blind Citizens Australia consultee observed that service might be possible for people who have gone to sighted school but much harder for those who did not or who do not have a good grasp of technology.[43]
• A person is concerned about being more easily identifiable in the community in a high-profile trial, particularly in a regional area. One person shared their concerns about this:
I have a real concern about standing out and not being able to blend in with other jurors. Country people who are blind or vision impaired tend to be noticed. My concern is serving on a jury and having someone approach me whilst I’m out shopping because they have recognized me from a case and want to express their opinion on the case/verdict. Or abuse me because they didn’t agree with the jury’s decision.[44]
• A person considers that the adjustments are unsatisfactory. Deaf Victoria consultation participants explained:
If supports are not satisfactory for example if they want captions and the screen provided is too small or not in the right place, or if the interpreters booked are not suitable to work with them. In other words, they would not be excused because they are deaf or hard of hearing, but because the appropriate access tools are not available to allow them to serve as a juror.[45]
16.41 The academics we consulted acknowledged that being a deaf juror would be exhausting and cognitively demanding, so some people may not want to serve. However, Professor Napier noted that the deaf people she had spoken to said that the excuse categories should be the same as for the general community, and that many of them felt that they would perform their civic duty just as others are required to.[46]
Excuses should only be available for the consequences of disability
16.42 The Commission does not think there should be an excuse as of right for disability. We acknowledge that doing so would make the excuse application process simple for a person from the subject groups. However, this approach reinforces the notion that people in the subject groups do not have the same rights and obligations in civil society as others. Excuse for disability as a right may perpetuate cultural misconceptions that people with disability cannot contribute to society.
16.43 The Commission agrees with Juries Victoria’s observation that the existing ‘good reason’ provision in section 8 is broad enough to allow people to be excused by Juries Victoria for reasons relating to the consequences of their disability rather than the disability itself.[47] ‘Good reasons’ include:
• illness or poor health
• substantial hardship to the person
• any other matter of special urgency or importance.[48]
16.44 The excuse ‘for good reason’ approach reflects the principle that people in the subject groups have the same rights and obligations in civil society as others. It subverts cultural misconceptions about the capabilities of people with disabilities.
16.45 This approach follows the example of the ACT and is in line with the recommendations from other Australian law reform bodies in Western Australia, New South Wales and Queensland. It is also in line with comparable international jurisdictions including the United Kingdom and the United States.
16.46 There may be situations where a person’s disability is so profound that they may never be able to serve or ever feel comfortable serving as a juror. In this situation, the person should continue to be able to apply to be permanently excused on the grounds of disability.[49]
16.47 A person who is permanently excused from jury service can waive that exemption later if they wish.[50] This provides a safeguard, for example, for circumstances where a person develops a disability later in life and does not feel comfortable serving, but over time becomes accustomed to using adjustments and changes their mind about wishing to serve.
Data should be collected about the reasons for excuse
16.48 Data should be retained about when a person from the subject groups seeks to be excused and for what reason. This should include data about adjustments that are offered that are unsatisfactory to the person from the subject groups. This will help to develop Juries Victoria’s understanding of what steps it can take to assist people to serve and may encourage future investment in new adjustments.
The excuse process should not be difficult
16.49 There should not be an overly burdensome process to seek to be excused for ‘good reason’. Vision Australia gave an example:
if it comes out that there are going to be complex documents submitted in evidence, and a person says that they don’t have the skill to read them, they shouldn’t have to prove that inability.[51]
16.50 At present, the Juries Victoria approach is geared towards excusing people in the subject groups. Comments from the Juries Commissioner suggested that Juries Victoria takes a flexible approach to this issue and routinely talks to people about their level of comfort with the idea of serving:
If the excuse is based on a medical issue, JV will ask for a medical certificate. For any other reason, JV makes individual assessments based on the conversations it has with people …[52]
We deal with these on a case by case basis. Sometimes, a person will call (if vision impaired) and with enough detail of that impairment, we’ll excuse them over the phone. Sometimes, a person who is profoundly deaf will use the interpreter service and call, and again, we’ll excuse over the phone. If they give sufficient information over the phone and it is clear (by that information) they are unable to do jury service, we’ll excuse. Often, they will complete the eligibility form (paper or online) and provided sufficient detail is given, we’ll process the application without a medical certificate.[53]
16.51 Juries Victoria advised that they deal with 200,000 people a year and hold one-on-one discussions with many people about special requirements to enable them to serve.[54]
Juries Victoria should provide information about the excuse process
16.52 Juries Victoria should publish material explaining the operation of the excuse process for people in the subject groups. This would help to allay concerns about serving. Information about excuse should be included on the Juries Victoria website with information about seeking adjustments. Juries Victoria should encourage and make it easy for people from the subject groups to talk to Juries Victoria about their needs and discuss excuse options.
16.53 For example, the Juries Victoria website and the questionnaire could state: ‘If you are deaf, hard of hearing, blind or with low vision, you can still serve on a jury if reasonable supports can be provided to enable you to perform your duties. Contact JV ahead of time to discuss what support you might need to attend. If you do not think you will be able to serve because of a reason associated with your disability, you can apply to JV to be excused from jury duty.’
16.54 An example of a good reason should be provided on the website; however, a detailed list should be avoided. Examples might include:
• I have recently become blind or deaf.
• I have recently received new technology/new guide dog and do not presently feel comfortable to serve.
• I am worried about the idea of having to serve with multiple Auslan interpreters that I do not know.
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Recommendation 37. The Juries Victoria website should provide information about the excuse process and provide examples for people from the subject groups. |
Clarifying the courts’ power to excuse in the Juries Act
16.55 In the context of upholding the right to a fair trial, the Supreme Court raised the question of whether section 32(3)(b) of the Act could be exercised on the Supreme Court’s own motion.[55] That section states:
(3) The court may excuse a person from jury service on the trial if the court is
satisfied that the person—
(b) is unable to serve for any other reason.
16.56 The provision applies when jurors have been balloted to a panel and the judge has provided information about the trial to the prospective jurors. The section outlines that after information is provided to the panel the court must call on persons on the panel to identify themselves if they seek to be excused.
16.57 It is possible that the power in section 32(3) could be read as only coming into operation if a panel member seeks to be excused. For that reason, we recommend that the legislation is clarified so that it is clear that the court may act on its own motion in the necessary circumstances.
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Recommendation 38. The Juries Act should be amended to clarify that section 32(3) may be exercised by the courts on their own motion to excuse a person from the empanelment process for a trial. |
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Consultation 1 (Blind Citizens Australia).
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Currently provided for in the Juries Act 2000 (Vic) s 8.
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Ibid s 8(2).
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Ibid s 8(3).
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Ibid s 9 (3), (4).
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Ibid s 7.
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Ibid ss 11 and 12, respectively. The order not to perform jury service under section 12 can be for whole or part of jury service, for a longer period, or permanently. The Juries Commissioner can also make an application under section 12 if they consider that ‘a person may not be able to perform the duties of a juror’.
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Ibid s 32(3), (4).
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Ibid.
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Juries Act 1967 (ACT) s 11.
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Juries Regulation 2018 (ACT) sch 1 table 1.4 item 8.
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Juries Act 1967 (ACT) s 14(1).
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Ibid s 14(2).
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Ibid s 14(1).
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We discuss recent changes to the law in the United Kingdom regarding British Sign Language interpreters in Chapter 10.
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Juries Act 1974 (UK) s 9B. This power is exercised by the judge. This Act only applies to England and Wales.
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Ibid s 9(2).
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Consultation 14 (Jury Commissioner, New York State Courts in Rochester, Monroe County, United States).
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Ibid.
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Consultation 15 (Representatives of High Court and District Courts of New Zealand).
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Ibid.
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See Law Reform Commission of Western Australia, Selection, Eligibility and Exemption of Jurors (Discussion Paper Project No 99, September 2009) 117; Queensland Law Reform Commission, A Review of Jury Selection (Report No 68, 2011) 258 [9.26] Recommendation 9.1.
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New South Wales Law Reform Commission, Jury Selection (Final Report No 117, September 2007) Recommendation 24.
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Ibid 100 [5.16]. We note that in 2006 the New South Wales Law Reform Commission recommended that a person who is blind or deaf should be able to participate with supports but should also ‘have an unqualified right to be exempt from jury service’: New South Wales Law Reform Commission, Blind or Deaf Jurors (Report No 114, September 2006) 58 [4.7].
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Queensland Law Reform Commission, A Review of Jury Selection (Report No 68, 2011) 284 [9.118].
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Consultation 20 (Victorian Equal Opportunities and Human Rights Commission).
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Submission 10 (Vision Australia).
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Consultation 17 (Youth Disability Advocacy Service (YDAS)).
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Position Statement 1 (Blind Citizens Australia).
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Consultation 24 (Alastair McEwin AM, Royal Commissioner, Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability, in his personal capacity).
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Consultation 8 (Brent Phillips).
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See, eg, Online Survey (Response 15).
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Online Survey (Response 2).
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Consultation 24 (Alastair McEwin AM, Royal Commissioner, Royal Commission into Violence, Abuse, Neglect and Exploitation of People with Disability, in his personal capacity).
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Consultation 6 (Deaf Victoria and community participants).
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See, eg, Consultation 25 (Peter Ward, Partner, Galbally and O’Bryan Lawyers); Online Survey (Response 17).
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Online Survey (Response 19).
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Online Survey (Response 13).
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Submission 13 (Juries Victoria).
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Submissions 10 (Law Institute of Victoria), 11 (Victoria Legal Aid); Consultation 16 (Office of Public Prosecutions Victoria).
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Submission 14 (County Court of Victoria).
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Submission 11 (Supreme Court of Victoria).
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Consultation 1 (Blind Citizens Australia).
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Submission 5 (Name withheld). Similar concerns about personal safety as jurors have been expressed by jurors outside the subject groups: see Chris Vedelago and Adam Cooper, ‘“Weird Things Happen”: Inside the Jury Room and Why Sometimes Trials Are Aborted’, The Age (online, 13 February 2022).
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Consultation 6 (Deaf Victoria and community participants).
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Consultation 3 (Academics: Professor Jemina Napier (Heriot-Watt University), Professor Sandra Hale (University of New South Wales), Associate Professor Mehera San Roque (University of New South Wales)).
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Consultation 10 (Juries Victoria).
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Juries Act 2000 (Vic) s 8(3).
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They may apply for permanent excuse under ibid s 9(4)(b).
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Ibid s 15.
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Consultation 7 (Vision Australia).
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Consultation 10 (Juries Victoria).
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Information provided by Juries Victoria to Victorian Law Reform Commission, 9 June 2021.
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Consultation 10 (Juries Victoria).
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Submission 11 (Supreme Court of Victoria).