FEDERAL COURT OF AUSTRALIA
Anderson v BYF19 [2019] FCA 1959
File number: NSD 745 of 2019 Judge: ABRAHAM J Date of judgment: 22 November 2019 Catchwords: CONTEMPT OF COURT – sentencing – contempt of the Australian Criminal Intelligence Commission – contempt punishable as contempt of Federal Court – respondent in contempt by refusing to answer questions in examination – where respondent pleaded guilty – where respondent did not subsequently purge contempts despite opportunities to do so – fixed term of imprisonment imposed Legislation: Australian Crime Commission Act 2002 (Cth) ss 7, 7A, 7C, 20, 21, 22, 28, 30, 34A, 34B
Criminal Code 1995 (Cth)
Federal Court of Australia Act 1976 (Cth) s 31
Federal Court Rules 2011 (Cth) Part 42
Cases cited: Allbeury v Corruption and Crime Commission [2012] WASCA 84; (2012) 42 WAR 425
Anderson v DKH18 [2018] FCA 1571
Anderson v XLVII [2015] FCA 19
Australian Competition and Consumer Commission v Info4pc.com Pty Ltd (2002) 121 FCR 24
Australian Competition and Consumer Commission v Jutsen (No 6) [2012] FCA 809
Corruption and Crime Commission v Allbeury (No 2) [2011] WASC 26
Elomar v The Queen [2014] NSWCCA 303; (2014) 300 FLR 323
Hannaford v HH [2010] FCA 1214; (2010) 205 A Crim R 366
Hannaford v HH (No 2) [2012] FCA 560; (2012) 203 FCR 501
Hughes v Australian Competition and Consumer Commission [2004] FCAFC 319; (2004) 247 FCR 277
Kazal v Thunder Studios Inc (California) [2017] FCAFC 111; (2017) 256 FCR 90
Louis Vuitton Malletier SA v Design Elegance Pty Ltd [2006] FCA 83; (2006) 149 FCR 494
Qutami v R [2001] NSWCCA 353; (2001) 127 A Crim R 369
R vHinchliffe [2013] NSWCCA 327
R v Palu [2002] NSWCCA 381; (2002) 134 A Crim R 174
Sage v ZZ (No 2) [2015] FCA 450; (2015) 234 FCR 251
The Queen v Pham [2015] HCA 39; (2015) 256 CLR 550
Wong v The Queen [2001] HCA 64; (2001) 207 CLR 584
Wood v Galea [1995] NSWSC 100; (1995) 79 A Crim R 567
Vaysman v Deckers Outdoor Corporation Inc [2011] FCAFC 17; (2011) 276 ALR 596
Date of hearing: 15 October 2019 Registry: New South Wales Division: General Division National Practice Area: Federal Crime and Related Proceedings Category: Catchwords Number of paragraphs: 86 Solicitor for the Applicant: Mr C Hutchins of Australian Government Solicitor Counsel for the Respondent: Avni Djemal Solicitor for the Respondent: Zahr Partners ORDERS
NSD 745 of 2019 BETWEEN: MR JEFFREY PHILIP ANDERSON, AN EXAMINER APPOINTED UNDER SECTION 46B OF THE AUSTRALIAN CRIME COMMISSION ACT 2002 (CTH)
Applicant
AND: BYF19
Respondent
JUDGE:
ABRAHAM J
DATE OF ORDER:
22 NOVEMBER 2019
THE COURT DECLARES THAT:
1.The respondent is guilty of the charge of contempt of the Australian Crime Intelligence Commission (formerly the Australian Crime Commission) in that,…
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- Anderson v BYF19 [2019] FCA 1959
- Case
- [2019] FCA 1959
- Decision Date
CaseChat Overview and Summary
The court had to determine the appropriate sentence for the respondent’s contempt of the ACIC. The key issue was whether the contempt was serious enough to warrant a custodial sentence, given the respondent’s refusal to answer questions during the examination and his failure to purge the contempt despite multiple opportunities.
The court found that the contempt was serious, as it undermined the effectiveness of the statutory scheme that authorised the compulsory examinations. The respondent's refusal to answer questions was deliberate, and he had been given ample opportunity to take legal advice. The court noted that fear of retribution was rarely a mitigating factor and that such fears would seriously inhibit the efficacy of the powers conferred by the ACC Act. Given these considerations, the court imposed a fixed term of imprisonment for 8 months, to be released after serving 4 months, with the remainder of the sentence suspended on the condition that the respondent be of good behaviour for 2 years.
The court further ordered that a warrant for the respondent’s committal to prison be issued, with the custodial period to commence from 22 November 2019 and expire on 21 March 2020. The respondent was also required to pay the applicant’s costs of the application. The orders previously made prohibiting the publication of the respondent’s name and suppressing access to the court file were to continue. The parties were granted liberty to apply in certain circumstances.
Orders
Orders of the court
1. The respondent is imprisoned for a period of 8 months, to be released after serving 4 months, the remainder of the sentence to be suspended on the basis that the respondent be of good behaviour for a period of 2 years.
2. The custodial period of 4 months imprisonment to date from 22 November 2019 to 21 March 2020, following which the balance of the sentence is suspended with the period of good behaviour for 2 years commencing on 22 March 2020 and expiring on 21 March 2022.
3. A warrant for the respondent’s committal to prison be issued and with a copy of these Orders, be provided to Corrective Services NSW.
4. The parties be at liberty to apply in the event that the respondent purges his contempt before the expiration of the period of 4 months imprisonment.
5. The applicant have liberty to apply in relation to the execution of the remainder of the sentence, if after being released on that condition, the respondent does not comply with it.
6. The orders previously made prohibiting the publication of the respondent’s name, and suppressing access to the court file are to continue.
7. The respondent is to pay the applicant’s costs of the application to be assessed if not agreed.
8. There be liberty to apply.
Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.
Background
Background to the litigation
Evidence
Evidence Before The Court
Decision
Reasons for decision
Full text does not contain this section.
Ratio Decidendi
Legal Principle Established
In any event, I note that the considerations to be taken into account on sentence for contempt, as illustrated by the non-exhaustive list referred to above, are not relevantly different from those applied in the sentencing of Commonwealth offences. Moreover, the range of sentences available, are necessarily limited by s 34B(5) of the ACC Act. Consideration There is no doubt that in the context of the statutory scheme, this offence of contempt is properly characterised as serious. The respondent’s approach in refusing to answer questions undercuts the effectiveness of the scheme which authorises these compulsory examinations. Indeed, as remarked upon in previous cases, the examination processes would be hamstrung if all witnesses adopted the approach that the respondent has taken. The investigations of which the examination was a part, are of significant importance to the protection of the broader community. The serious impact on the community of illicit drug use and supply, and associated crime is uncontentious. General deterrence must necessarily play a prominent role in any such sentence. These contempts were deliberate. The respondent was repeatedly informed of the consequences of his refusal to answer the questions and given every opportunity to take legal advice and to consider that advice, with the hearing being adjourned specifically for that reason on more than one occasion. The respondent was represented by counsel and a solicitor. The respondent’s explanation for refusing to answer these questions is a fear for his family for potential retribution. This fear was a generalised fear, as the respondent did not identify any specific threat. To the contrary, the respondent said there had been no threat made to his family. The respondent confirmed during the examination that no-one but his lawyers were aware of his attendance before the ACIC. The respondent’s submission on sentence was that the same fears that motivated him to decline to answer questions that would implicate the owners of the money, would also motivate him to not specify the source of those fears. However, that was not the respondent’s explanation during the examination and is inconsistent with the answer actually given, that there had been no threat to his family. Fear of retribution is a matter that will rarely be given mitigatory weight: GPY18 at [31] citing R v Drever [2010] SASCFC 27 at [24] and Allbeury at [42]-[43]. Relevantly, in Hannaford (No. 2) at [33], Dodds-Streeton J referred to the comments of Martin CJ in Corruption and Crime Commission v Allbeury (No 2) [2011] WASC 26 (Allbeury (No 2)) at [33]:His Honour also considered that as it was inherently probable that those summoned to give evidence would claim to fear retribution if they co-operated “it would seriously inhibit the efficacy of the powers conferred by Pt 4 of the CCC Act, and the achievement of the important public policy objective underpinning the conferral of those powers, if an asserted fear of retribution were to be given significant mitigating weight when sentence is passed…”