When Can Someone Who Has Posted Bail For An Accused Person Recover The Amount Of The Surety? (victoria)

Bail is the release from the custody of police orthe Crown Proceedings Act 1958 that the amount
prison officers of someone who is charged withof the bail be forfeited and the amount
an offence. The release is subject to anundertaken by the surety be paid to the Crown.
undertaking that the accused person will appear atWhere an order is made, a surety may apply to
court to answer the charge in the future.the court that made the original order to vary or
Bail is like a contract. The person who does notrescind such order on the ground that it would be
appear when on bail can be charged with aunjust to require the surety to pay the amount
criminal offence.undertaken to be paid having regard to all the
Bail takes many forms.circumstances of the case. The court is
Most people are bailed "on their own undertaking".empowered to vary or rescind the order and
This does not involve any money or property tocancel any warrant for forfeiture of surety
be surrendered.security.
On other occasions, the accused person will beThere are two leading Victorian decisions on the
required to deposit a sum of money. This ispower of the Crown to seek forfeiture of surety
generally done by persons other than thesecurity. These cases are Re Condon (September
accused. This person is called a surety. A surety is1972) and Re Wilkinson (September 1981). Both
a person who guarantees, by putting up security,were decisions of Crockett, J., of the Supreme
usually by way of a sum of money, that theCourt of Victoria.
accused person will appear at the date and placeBoth decisions stand for the following propositions:
specified in the bail bond. If the accused does not1 The surety seeking relief must be a "genuine
turn up at court to answer the bail, the amountsurety" - in other words, must not be a front for
put up may be forfeited to the Crown.the person who is really supplying the funds for
Sureties place their property at considerable risk.the bail bond.
For this reason, Section 23 of the Bail Act 19772 The surety must take all reasonable steps to
allows sureties to apply to the court to which thesecure the attendance of the accused in all the
accused person would be required to surrendercircumstances. In determining whether or not
himself or herself under the bail conditions to applyreasonable steps are taken, the surety must take
to discharge the surety from further liability underpositive action and will not succeed if he or she
the bail bond.merely relies upon a belief, however well-founded,
The accused person has the right to be broughtthat the accused will in fact answer bail. Even
before the court when the surety makeswhere the surety can establish that he or she did
application. The accused person may be preparedtake all reasonable steps to ensure the
to relinquish his or her liberty and remain in prisonattendance of the accused at his or her trial, the
on remand until the date of the trial.surety must also establish that it would be unjust
Alternatively, the court may ask whether thein all the circumstances not to vary or rescind the
accused is able to find another surety or otherorder forfeiting the bail security.
security for his or her appearance at the trial3 The surety must establish clear evidence of
date. If this is not possible, the likely result is thatfinancial hardship if the surety is forfeited. Mere
the accused will be committed to prison oneconomic inconvenience is insufficient.
remand.4 The surety must apply by way of summons
There is a procedurewhere the accusedwhich should be served on the Police Informant
voluntarily agrees to be placed in prison onand on the Crown Prosecutor (if known). The
remand pending trial or is unable to find ansummons should be supported by an affidavit.
alternative surety.The surety should expect to be cross-examined
The procedure is different where the accused hasand should be available to give evidence.
absconded and fails to surrender himself orIndependent evidence of financial hardship in the
herself for trial.form of affidavit or viva voce from family
In these circumstances, the Crown or prosecutingmembers or close relatives and friends should also
authority may seek an order under Section 6 ofbe considered.