A 'Submission of argument' is a written statement of the arguments and issues you want the Court of Appeal to consider. The outline should be no more than 10 pages.
The written outline or argument should:
- identify any errors the trial Judge is said to have made;
- be concise;
- if including any statement about the facts, give reference to the relevant page of the record of evidence at trial in the record book eg - R.12, L30 or LL30-45- ie record book page 12, line 30 or lines 30-45;
- generally only refer to evidence actually given before the court at trial (not at the committal);
- include all points of law that you consider were wrongly decided; and
- include references to all factual matters that you consider were favourable to you, which should have caused the jury to have a reasonable doubt about your guilt.