SUPREME COURT OF SOUTH AUSTRALIA
(Court of Appeal: Criminal)
DENG v THE KING
[2023] SASCA 35
Judgment of the Court of Appeal
(The Honourable President Livesey, the Honourable Justice Doyle and the Honourable Justice Bleby)
6 April 2023
CRIMINAL LAW - SENTENCE - SENTENCING ORDERS - NON-CUSTODIAL ORDERS - SUSPENDED SENTENCE OF IMPRISONMENT
CRIMINAL LAW - APPEAL AND NEW TRIAL - VERDICT UNREASONABLE OR INSUPPORTABLE HAVING REGARD TO EVIDENCE - APPEAL DISMISSED
CRIMINAL LAW - APPEAL AND NEW TRIAL - APPEAL AGAINST SENTENCE - GROUNDS FOR INTERFERENCE - SENTENCE MANIFESTLY EXCESSIVE OR INADEQUATE
APPEAL AND NEW TRIAL - APPEAL - GENERAL PRINCIPLES - RIGHT OF APPEAL - WHEN APPEAL LIES - ERROR OF LAW - PARTICULAR CASES INVOLVING ERROR OF LAW - FAILURE TO GIVE REASONS FOR DECISION - ADEQUACY OF REASONS
CRIMINAL LAW - EVIDENCE - MATTERS RELATING TO PROOF - BURDEN OF PROOF
The appellant was charged with one count of recklessly causing serious harm, contrary to s 23(3) of the Criminal Law Consolidation Act 1935 (SA) (‘CLCA’).
The circumstances of the offending were that during a physical altercation between the appellant and the complainant (who was in a relationship with the appellant’s former partner), the appellant bit off a piece of the complainant’s lower lip, causing her serious harm. The prosecution case was that the appellant instigated the physical altercation. The essential issue at trial was whether the evidence excluded, as a reasonable possibility, that the complainant instigated the altercation, with the appellant acting in self-defence.
Following a trial by judge alone, the appellant was convicted. The judge accepted the prosecution case that the appellant instigated the altercation, and rejected as a reasonable possibility that the appellant was acting in self-defence.
The appellant was sentenced to five years imprisonment, with a non-parole period of two years. The judge declined to suspend the appellant’s sentence, and also declined to make an order that the sentence be served on home detention.
The appellant appeals both her conviction and sentence.
Conviction appeal
The grounds of appeal against conviction are as follows:
1.the judge erred in his application of the burden of proof in relation to the issues to be determined;
2.the judge failed to bring to account the evidence of prosecution witnesses other than the complainant in undermining the reliability of the complainant and in supporting the appellant’s evidence;
3.the judge erred in concluding, in relation to the appellant’s account and the injuries she suffered, that “it would be very difficult to see why she sustained only one small abrasion over the right eyebrow”;
4.the judge erred in his approach to the legal issues by determining that the appellant intended to disfigure when she was not charged with an intention to cause any degree of harm;
5. the judge’s reasons were inadequate; and
6.the verdict of the judge was unreasonable or cannot be supported having regard to the evidence.
Held, per the Court, granting permission to appeal but dismissing the appeal:
1. none of the grounds of appeal against conviction…
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- Deng v The King [2023] SASCA 35
- Case
- [2023] SASCA 35
- Decision Date
CaseChat Overview and Summary
The legal issues before the Court included whether the verdict of guilty was unreasonable or insupportable having regard to the evidence, and whether the sentence imposed was manifestly excessive or inadequate. Specifically, the Court considered whether the sentencing judge erred in imposing an immediate custodial sentence given the appellant's lack of prior convictions and responsibility for five children, and whether the judge sentenced the appellant on the basis of a specific intention to harm and disfigure Ms Gai when the charge only involved reckless intent. A further issue was whether the judge failed to consider provisions of the Sentencing Act 2017 (SA) that would have allowed for a partially suspended sentence.
The Court dismissed the appeal against conviction, finding that the verdict was not unreasonable. Regarding the sentence appeal, the Court found that the sentencing judge had not erred in his findings of fact or in his assessment of the appellant's intention. The Court noted that the judge had considered the appellant's background, including her refugee status and responsibility for her children, but concluded that the gravity of the offending, which involved a violent and unprovoked attack, warranted an immediate custodial sentence. The Court also found that the sentencing judge had properly considered the relevant provisions of the Sentencing Act and that there was no error in declining to impose a partially suspended sentence or a home detention order.
The Court granted permission to appeal against sentence but dismissed the appeal. The sentence of five years imprisonment with a non-parole period of two years was upheld. The appellant had served 22 days in custody before being granted bail pending the appeal.
Orders
Orders of the court
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Background
Background to the litigation
Evidence
Evidence Before The Court
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
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