Summary

Keywords

Criminal law - Elements of offence - Criminal law - Statutory interpretation - Elements of offence - Failure to stop at scene of accident - Meaning of “civil or criminal liability” in s. 252(1) of Criminal Code - How principles of statutory interpretation should apply to the interpretation of penal statutes - Whether conviction of appellant for failure to stop at scene of motor vehicle accident is a miscarriage of justice - Criminal Code, R.S.C. 1985, c. C-46, s. 252(1)(b).

Summary

Case summaries are prepared by the Office of the Registrar of the Supreme Court of Canada (Law Branch). Please note that summaries are not provided to the Judges of the Court. They are placed on the Court file and website for information purposes only.

On December 29, 2013, Mr. Seipp was involved in a motor vehicle collision while driving a stolen vehicle. A passenger in the other vehicle was injured. Mr. Seipp fled without providing his name or address. He was charged with a number of offences including fleeing the scene of an accident, an offence under s. 252(1)(b) of the Criminal Code, R.S.C. 1985, c. C-46. At trial, he testified that a friend previously had invited him to drive around in the vehicle, he had dropped her off, and he had continued driving the vehicle until the accident. He testified that he fled from the collision because he suspected the vehicle was stolen. At the end of the defence’s case, the trial judge asked defence counsel if she was in a position to admit that the evidence established guilt on any counts. Defence counsel in part submitted that the offence of failure to stop at the scene of an accident and provide a name and address had been proved. The trial judge in part convicted Mr. Seipp of that offence. Mr. Seipp appealed this conviction and other convictions. The Court of Appeal dismissed the appeal.