The evidence relied on by the applicant in support of this application came to light as a result of evidence given by way of private and public examinations to the Independent Broad-based Anti-corruption Commission (‘IBAC’). From this, the applicant can now adduce evidence that an officer or officers of Victoria Police fabricated evidence relating to statements made by Senior Constable Miller. In particular, a written statement made by Senior Constable Pullin which was in fact made 10 months after the murders, was expressed to be, and subsequently adopted at the committal as, a statement made only some four hours after the events in issue. The trial proceeded on the basis that the statement recorded the substantially contemporaneous recollection of the witness. The statement included material matters which were not included in an initial statement which was in fact made four hours after the relevant events. The second statement was put forward in the prosecution brief without disclosure of its falsity as to the stated date of its making and without disclosure of the existence or contents of the original statement. It appears that Senior Constable Pullin also gave false evidence at the committal as to the date of the making of the second statement.