The appellant appealed his conviction and sentence for offences arising from a high-speed car chase where a police officer was struck and seriously injured.
The main issue at trial was the identity of the driver.
The trial judge admitted an unsworn videotaped statement from a passenger identifying the appellant as the driver, as the passenger claimed no memory at trial due to heroin use.
The Court of Appeal upheld the admission of the statement, finding it met the threshold requirements of necessity and reliability.
The sentence appeal was also dismissed, with the court noting the appellant's lengthy criminal record and the deliberate attack on a vulnerable police officer.