EVIDENCE - Admissibility - Hearsay rule - Exceptions - Necessary and reliable evidence

Law360 Canada ( September 25, 2024, 1:41 PM EDT) -- Appeal from a judgment of the Court of Appeal of Quebec which upheld the convictions of the appellant for assault with a weapon, using an imitation firearm in the commission of assault and uttering threats. The appellant, in the presence of KA and Fares, threatened the complainant with what looked like a pistol. The next day, KA was arrested and taken into custody. He was questioned by police and signed a written statement. In his statement, which was not under oath nor recorded, he admitted that the day before he had been in possession of two pellet pistols belonging to Fares. At Fares’ request, he gave one of the pistols to the appellant. He indicated that the appellant pointed the pistol at the complainant while threatening him then tried to erase his fingerprints off the pistol before giving it back to him. KA added that the pistols were now in his home. After a search, the police effectively recovered the pistols at his residence. At trial, the Crown called KA as a witness, but KA claimed to have no recollection of the events. The Crown asked to introduce KA’s out-of-court statement into evidence as hearsay. The trial judge allowed it, concluding that it had features of substantive reliability considering the seizure of the pistols which he considered to be corroborative evidence and the circumstances in which the statement had been made. The majority of the Court of Appeal dismissed the appeal while the dissenting judge would have excluded the statement and ordered a new trial. The appellant argued the Court of Appeal erred in law in upholding the decision to admit KA’s statement into evidence based on the principled exception to the hearsay rule....

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