Key legal question
Whether the accusation sufficiently covered the subjective element and the defence rights were violated
Extracted holding
No. In a deliberate-offence case, the indictment based on the summary penalty order sufficiently described the facts; no additional subjective detail was required.
Extracted reasoning
The authority cited the intentional offence provision, which signaled that it proceeded on intent. For an intentional offence, the factual narrative and legal qualification were enough to inform the defence.