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Drug offences Tom Spohr Drug offences Tom Spohr

Barber v R [2025] NSWCCA 179

In this judgment the CCA has determined that, where an accused accrues an onus of proof to establish that the drugs in their possession was not for the purpose of supply, they must establish (on the balance of probabilities) that the whole of that portion in their possession was for a purpose other

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Sentencing Tom Spohr Sentencing Tom Spohr

R v Sabbah [2025] NSWCCA 203

In this case the Court of Criminal Appeal (‘CCA’) examined the ‘relatively new’ offence in s 37(1A) of the Crimes Act of intentionally choking, and set out a range of factors which are relevant to assessment of the objective seriousness of the offence.

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Sentencing Tom Spohr Sentencing Tom Spohr

Comer v R [2025] NSWCCA 164

In this decision the Court of Criminal Appeal has considered what it means for an offence to be a ‘related offence’ under for the purposes of summary offences being sentenced together with indictable offences.

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Sentencing Tom Spohr Sentencing Tom Spohr

Towers v R [2025] NSWCCA 142

In this decision the Court of Criminal Appeal (‘CCA’) has drawn attention to the importance of keeping the objective and subjective factors of sentencing separate – and more particularly the importance of not allowing the existence of a guideline judgment to detract from the obligation to make disti

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Sentencing Tom Spohr Sentencing Tom Spohr

Wei v R [2025] NSWCCA 150

Where an offender is being sentence for a Commonwealth offence, and they have cooperated with authorities, this decision has drawn attention to the importance of a need for separate conclusions about what discount (if any) should be allowed by reason of the assistance.

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Evidence Tom Spohr Evidence Tom Spohr

Wright v R [2025] NSWCCA 108

The Court of Criminal Appeal (‘CCA’) has held that a tendency notice served only a few days before trial can still amount to ‘reasonable notice’ under the Evidence Act, provided it causes no actual prejudice to the accused, and despite requirements for it to be served typically many months earlier.

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Mental health Tom Spohr Mental health Tom Spohr

Delaney v R [2025] NSWCCA 76

The Court of Criminal Appeal has held that for the purposes of the definition of ‘mental health impairment’, the mere presence or absence of drug use at around the time is not decisive. The real question is whether any mental health impairment is caused solely by whatever drugs are present in the ac

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Sentencing Tom Spohr Sentencing Tom Spohr

NK v R [2025] NSWCCA 73

In this decision the CCA has observed that, although general deterrence and an offender’s deprived upbringing may pull in opposite directions in sentencing, it is not correct to say that an increased need for general deterrence renders an offender’s reduced moral culpability irrelevant.

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Sentencing Tom Spohr Sentencing Tom Spohr

Rokovada v R [2025] NSWCCA 64

In this important decision, the Court of Criminal Appeal (‘CCA’) has held that a mere offer to plead guilty at committal may not secure a 25% discount if accepted later by the Crown, where the plea could have been entered to existing charges but wasn't formally made in court.

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Sentencing Tom Spohr Sentencing Tom Spohr

MacBlane v R [2025] NSWCCA 52

In this decision, one judge has drawn together 15 years worth of reasons why it is now rarely appropriate to cite the guideline judgment for sentencing in break, enter, and steal matters – and pointed out that practitioners who uncritically do so will likely lead the court into error.

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Evidence Tom Spohr Evidence Tom Spohr

R v Walker [2025] NSWCCA 62

In this decision about a jury direction, the Court of Criminal Appeal (‘CCA’) has commented on the emerging view that in-person evidence has advantages over video evidence. The obiter comments are likely to be worthwhile reading for any practitioner making or opposing an application that a witness g

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Sentencing Tom Spohr Sentencing Tom Spohr

RG v R [2025] NSWCCA 36

Where a sex offender has themselves been abused as a child, that earlier abuse against them may be used in mitigation if the applicant establishes on the balance of probabilities that the abuse occurred, that it was a ‘contributing factor’ in their offending, and it can be shown that there are relev

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Sentencing Tom Spohr Sentencing Tom Spohr

Sampson v R [2025] NSWCCA 25

In this judgment the Court of Criminal Appeal (‘CCA’) has held that, unfortunate as it may be, the mandatory sentencing discount scheme requires judges to impose post-discount sentences which cannot be rounded to even months. It would appear many head sentences, at least, are set to become expressed

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Practice and procedure Tom Spohr Practice and procedure Tom Spohr

Dimitriou v R [2025] NSWCCA 18

The Court of Criminal Appeal (‘CCA’) has held that in a prosecution for the offence of Fraud, it is not necessary for the Crown to prove that the accused intended the financial advantage or financial disadvantage or was reckless as to that outcome. The element of deception in this context already re

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Mental health Tom Spohr Mental health Tom Spohr

R v Skapik [2025] NSWCCA 19

In this decision the CCA has held that the Commonwealth summary mental health diversion provisions are not limited to acute and serious mental health conditions such as might see a person be involuntarily detained. The concept of ‘mental illness’ in this context is broader and provides a measure of

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Drug offences Tom Spohr Drug offences Tom Spohr

Salameh v R [2024] NSWCCA 239

The Court of Criminal Appeal (‘CCA’) sat a full bench in this case in order to set the record straight on the mental element in drug supply matters. They held that the prosecution is not required to prove that the accused knew the identity of the actual drug. All that is required is that the prosecu

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Sentencing Tom Spohr Sentencing Tom Spohr

BAP v R [2024] NSWCCA 206

In this decision the Court of Criminal Appeal (‘CCA’) has endorsed the proposition that a plea at a ‘super call-over’ may, in appropriate cases, attract a discount which is additional to the discount for the plea of guilty.

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Sentencing Tom Spohr Sentencing Tom Spohr

Vamadevan v The King [2024] NSWCCA 223

In a decision that creates a crisp distinction between offenders committing federal offences as distinct from NSW State-based offences, the CCA has held that, whilst Intensive Correction Orders (‘ICO’s’) are available for federal offenders, s 66 of the Crimes (Sentencing Procedure) Act 1999 (NSW) do

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