Judge finds all charges, including obtaining by deception, involve ‘corrupt intent’
The New Zealand Supreme Court has declined an extension of time to seek leave to appeal sought by a man whom a jury found guilty of 14 bribery charges, four charges of corrupt use of official information, and two charges of obtaining by deception.
In Goel v R [2026] NZSC 96, the applicant was tasked with managing the Westland District Council’s infrastructure assets. Charges arose from his involvement in assisting associates with securing service contracts.
The High Court determined that all charges involved “corrupt intent,” denied severance, and let the Crown utilise the evidence on a cross‑propensity basis.
According to the court, the jury could use the evidence as propensity evidence across the charges if they found that it established bribery, the corrupt use of official information, or obtaining by deception.
In a pre-trial decision, the Court of Appeal confirmed the High Court’s course.
The appeal court saw a propensity running through the evidence on all charges, specifically the applicant’s use of his position and information obtained therefrom to help third parties with their contractual dealings with his employer.
Before the Court of Appeal, the applicant sought leave to bring a conviction appeal. On 12 December 2025, the appeal court denied leave for being untimely.
Before the Supreme Court, the applicant asserted three grounds in an application for leave to appeal directly from the High Court of New Zealand:
The Supreme Court of New Zealand denied the application for an extension of time to apply for leave to appeal. The Supreme Court saw no justification for a direct appeal and no need to hear and determine the proposed appeal in the interests of justice.
In the first two proposed grounds of appeal, the Supreme Court found no question of general or public importance and no risk of a substantial miscarriage of justice.
According to the Supreme Court, regardless of the charges’ distinct legal and factual underpinnings, the evidence showed a specific state of mind under s 40(1)(a) of the Evidence Act 2006.
The Supreme Court saw no error in the Court of Appeal of New Zealand’s conclusion that the evidence was cross‑admissible, with its probative value outweighing the risk of unfair prejudice.
Regarding the proposed third ground of appeal, the Supreme Court acknowledged a potential question of general or public importance.
However, the Supreme Court held that the judge gave sufficient directions and directed the jury to ascertain that the evidence established facts underlying the alleged propensity and that a continuing pattern of repeated behaviour existed, whereas that high standard of proof was inapposite to propensity evidence.
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