The Crown brought several pre‑trial applications in a homicide prosecution seeking to admit statements made by the accused to police, evidence of disreputable conduct, post‑offence conduct, and hearsay statements of the deceased reflecting her state of mind prior to death.
The court reviewed the principled approach to hearsay admissibility, including the requirements of necessity and threshold reliability, and the balancing of probative value against prejudicial effect.
Numerous statements by the deceased to friends, family, and others were admitted where they reliably reflected her state of mind and potential motive related to the accused, while other statements were excluded as overly prejudicial, too remote, or constituting inadmissible hearsay about past events.
The court also ruled that various evidence of the accused’s alleged disreputable conduct and post‑offence behaviour could be admitted as circumstantial evidence relevant to motive and concealment.
