The appellant was convicted of sexually assaulting his stepdaughter.
At trial, the complainant's mother, who was a police officer, testified that she used trickery to obtain an admission from the appellant.
The trial judge accepted this evidence and found the mother was acting as a police officer, but no voir dire was held to determine the voluntariness of the statement.
The Court of Appeal held that given the trial judge's finding that the mother was acting as a person in authority, a voir dire was required.
The appeal was allowed and a new trial ordered.
