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Drug offences Tom Spohr Drug offences Tom Spohr

R v Narouz [2024] NSWCCA 14

In this decision the Court of Criminal Appeal (‘CCA’) has determined that the offence of driving with illicit drug in oral fluid is an offence of absolute liability, so that the defence of honest and reasonable mistake of fact is not available.

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Sentencing Tom Spohr Sentencing Tom Spohr

Robertson v R [2024] NSWCCA 22

Here the CCA has reiterated that where an offender commits an offence to pay off a drug debt or to fund their own habit, then the offence will typically not be for ‘financial reward’ in the way that is normally understood in the context of sentencing – but this amounts to the absence of an aggravati

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Sentencing Tom Spohr Sentencing Tom Spohr

DG v R (No 1) [2023] NSWCCA 320

In this decision the Court of Criminal Appeal (‘CCA’) has put to bed the question of whether a sentence of imprisonment can be reduced to enable consideration of an Intensive Correction Order (‘ICO’): it is not a permissible exercise of a sentencing judge’s discretion.

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Local Court Tom Spohr Local Court Tom Spohr

Brighton v RSPCA (NSW) [2023] NSWSC 1653

A Supreme Court judge, sitting alone, himself described this case as ‘arguably interesting’, involving, as it did, an unprovoked attack on a camel named Alice, the ‘barbaric’ killing of a dog by the owner, summary conviction, a successful appeal, remittal, and the eventual imposition of an ‘extraor

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Drug offences Tom Spohr Drug offences Tom Spohr

Bott v R [2023] NSWCCA 255

In this decision the Court of Criminal Appeal (‘CCA’) has held that, just because there is no hierarchy of the harm caused by drugs does not mean that there is no value in comparing drugs against one another in terms of their expected value, provided there is evidence to support that proposition.

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Sentencing Tom Spohr Sentencing Tom Spohr

Kljaic v R [2023] NSWCCA 225

In this first of a duo of (apparently unrelated) cases on the topic of when and how sentences can be backdated, the Court of Criminal Appeal (‘CCA’) has concluded that in appropriate circumstances an available means of recognising difficult conditions in custody is to backdate a sentence to a date b

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Sentencing Tom Spohr Sentencing Tom Spohr

Marai v R [2023] NSWCCA 224

This case also grapples with the question of back-dating sentences of imprisonment. Here, the CCA has held that in appropriate circumstances it may be appropriate to give full credit for time spent in immigration detention, even if the offender was technically on bail at the time.

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Criminal law Tom Spohr Criminal law Tom Spohr

Quinn v R [2023] NSWCCA 229

In this decision the CCA has confirmed the elements that the prosecution must prove when alleging that an accused was an accessory after the fact, and faintly, implicitly, bemoaned the fact that NSW remains the only Australian jurisdiction not to codify this area of the law.

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Federal sentencing Tom Spohr Federal sentencing Tom Spohr

Chan v R [2023] NSWCCA 206

For anybody worried that it wasn’t already sufficiently complicated to sentence federal offenders, fear not, because this decision of the Court of Criminal Appeal (‘CCA’) provides that when sentencing a federal offender, a court applying the three-step test in deciding whether to impose an Intensive

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Bail Tom Spohr Bail Tom Spohr

Bugmy v Director of Public Prosecutions (NSW) [2023] NSWSC 862

This decision of a single judge of the Supreme Court, holds that, the only precondition to a police officer arresting a person for breach of bail is a formation of the relevant belief as to a breach of bail – the officer is not obliged to consider alternatives like a warning before determining to ar

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Sentencing Tom Spohr Sentencing Tom Spohr

Brzozowski v R [2023] NSWCCA 129

The CCA has drawn out the fine distinctions between regret about consequences, and remorse as to the original offending which led to those consequences – and held that it is only the latter which can result in a finding leading to mitigation of a sentence for the purpose of s 21A(3)(i).

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Sentencing Tom Spohr Sentencing Tom Spohr

R v Sharrouf [2023] NSWCCA 137

In this decision the Court of Criminal Appeal (‘CCA’) has determined that the use of a s 10A (i.e. a conviction with no other penalty) should be rare in domestic violence offences where the offence is considered to be objectively serious.

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Evidence Tom Spohr Evidence Tom Spohr

Gardiner v R [2023] NSWCCA 89

In this decision the Court of Criminal Appeal (‘CCA’) has determined that although judges in judge-alone trials are entitled to take into account the demeanour of witnesses outside the witness box (for example in the dock, or in the well of the Court), the judge should immediately bring to the atten

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Evidence Tom Spohr Evidence Tom Spohr

Barney v R [2023] NSWCCA 85

In the course of considering this appeal, the Court of Criminal Appeal has discussed the concepts of ‘credibility’ and ‘reliability’ in a way that is likely to be useful for practitioners appearing in hearings and appeals at all levels.

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