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Documents which have been lodged with the Solicitor-General in relation to the Keogh Petitions
Author of this page: Dr Robert N Moles
Antecedents
See generally the discussion of witness immunity issues
This page contains the various related Complaints to the Medical Board
This document explains related problems with the Medical Board
In particular, it explains that Keogh is not a party to the proceedings before the Board and should not have been told by the
Board that he had to "prosecute" the Complaint before the Board.
The Solicitor-General Investigates -Background briefing
In May 2006 the Full Court of the Supreme Court of South Australia requested that they be provided with all documents which had been submitted to the Solicitor-General in relation to the Petitions of Henry Keogh. They have requested those documents in relation to the matter: No 1465 of 2005 Ross Alexander James, Plaintiff and Medical Board of South Australia, First Defendant Henry Vincent Keogh, Second Defendant. They are as follows:
The First Petition was submitted December 1996
The Second Petition was submitted August 2002
The Third Petition was submitted August 2003
Affidavits lodged with the Solicitor-General February 2004
Professor Anthony Ansford - full text - summary
Professor Ansford is the former head of forensic pathology in Queensland - full text
Dr Byron Collins - full text - summary
Dr Collins is a leading independent forensic pathologist from Melbourne - full text
Professor Stephen Cordner - full text - summary
Professor Cordner is the head of the Victorian Institute of Forensic Medicine - full text
Professor Malcolm Fisher - full text - summary
Professor Fisher is the head of Emergency Medicine at the Royal North Shore Hospital, Sydney - full text
The Anaphylaxis Report referred to in Professor Fisher's affidavit
Professor Maciej Henneberg - full text - summary
Professor Henneberg is a world authority on functional and forensic anatomy
Associate Professor Peter Scally - full text
Professor Scally is a director of radiology and a joint author of one of the leading texts on diagnotic medicine
Professor Gale Spring - full text - summary
Professor Spring is forensic photographer from the Royal Melbourne Institute of Technology
Associate Professor Anthony Thomas - full text - summary
Further affidavit of Associate Professor Anthony Thomas - full text
Professor Thomas has until recently been the head examiner for the Royal Australasian College of Pathology for
Australasia. His affidavit provides the most comprehensive study of problems in the forensic pathology in the Keogh case
Further written submissions were provided by Professor Douglas Henderson of Flinders Medical Centre Adelaide, and by Detective Chief Superintendent David Cook of the Metropolitan Police (UK) which are not available online.
Further Submissions November 2004
This is the list of documents provided to the Solicitor-General by Henry Keogh's counsel [Mr Borick QC]
in preparation for a meeting with him on 30 November 2004.
General pathology references and issues
Brief biographies of authors and editors referred to in submissions
Autopsy Standards in Australia, UK, Scotland and USA
Diagnostic difficulties of Drowning
Medical History of Deceased Essential
Allergies and Anaphylaxis as a possible cause of sudden death
Aortic Staining as a possible indicator of drowning
References to Possible Cause of Death
References to Possible Manner of Death
Extracts of transcript re: aortic staining and potassium release
References re: potassium release and its effects
Which hand used for grip? - Dr Manock
The Australian - Running on borrowed time
ABC Radio National - The Health Report - Sudden Cardiac Death
Memo from Professor Pounder re: "differential staining"
Memo from Dr Tony Thomas re: "differential staining"
Submissions February 2005
This list contains further submissions from Mr Borick QC. It contains, amongst other things, important legal submission on the developing law relating to miscarriages of justice and relevant information about applicable autopsy standards at the time of the autopsy in the Keogh case
Letter from Kevin Borick QC to the Solicitor-General
Summary of the Keogh case to date
Further grounds relating to a miscarriage of justice
Discussion of R v Osland 1998 High Court
Dr James - checking the work of Dr Manock
Dr Manock - the formulation of his opinion
Dr Manock - qualifications and background
Discussion of Yates v State of Texas 2005
Further submission on behalf of Dr Manock
Further submission response on behalf of Mr Keogh
Submissions October 2005
This series of submissions by Mr Borick QC results from further extensive work on the analysis of the legal principles relating to miscarriages of justice in Australia, the UK and the USA. It also includes the application for judicial review of the decision of the Medical Board.
Letter from Kevin Borick QC to Chris Kourakis QC Solicitor-General 10 October 2005
It contains the list of further materials forwarded to the Solicitor-General
A1 – Response to Solicitor-General’s letter of 17 August 2005.
A2 – Scally reply to Solicitor-General – with CV attached [available on request]
A3 – Statement of Michael Fielding [not available online]
B5 - The Appellate Treatment of Error at Trial in Australia
B5 - The Appellate Treatment of Error at Trial in UK Criminal Cases [Part one]
B6 - UK Criminal Cases [Part two]
B7 - The Appellate Treatment of Error at Trial in USA Criminal Cases
B8 - Gipp v The Queen - High Court Australia
B9 - R v Patrick Nichols - (UK CCA) relates to your matter 12
B10 - R v Pendleton - (UK - HL) - a summary - the leading case of principles in criminal appeals
B11 - Cooley v State of Western Australia a summary - adverse findings regarding medical prosecution witness
B12 - R v Mallard a summary. The important recent case from WA
Previously we submitted the appellant's submission to the SG. We now refer to the judgment of the High Court
B13 - Affidavit of Michael Sykes, solicitor
B13 - Affidavit of Henry Keogh
C14 - Application of the legal principles to the case of Henry Keogh
C15 Part one - summaries of UK cases 1947-1986
C15 Part two - summaries of UK cases 1997 to date
C16 A critical appraisal of the addresses of counsel in Henry Keogh's trial
D17 - The Medical Board - Application for Judicial Review Leave to serve granted by Perry J.
D18 - Finding of the Fitness to Practice Panel UK - Professor Sir Roy Meadow
[New Document] Professor Sir Roy Meadow Wins Appeal
D19 - Judicial Review - Draft Outline of Argument
E20 - Commentary re wrongful convictions - Canada
E21 - R v Jim Bromgard USA - a review
E22 - Article - The Myth of Fingerprints Relates to expert evidence and the "Daubert principle"
E23 - Introduction - the Honourable Fred Kaufman QC
F24 - Dr Byard research proposal "aortic staining" Commentary and FOI documents
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