SUPREME COURT OF SOUTH AUSTRALIA
(Court of Appeal: Criminal)
DRIVER v ATTORNEY-GENERAL (SA)
[2022] SASCA 13
Judgment of the Court of Appeal
(The Honourable Chief Justice Kourakis, the Honourable Justice Doyle and the Honourable Justice Bleby)
3 March 2022
CRIMINAL LAW - SENTENCE - POST-CUSTODIAL ORDERS - OTHER TYPES OF POST-CUSTODIAL ORDERS
CRIMINAL LAW - SENTENCE - SENTENCING ORDERS - ORDERS AND DECLARATIONS RELATING TO SERIOUS OR VIOLENT OFFENDERS OR DANGEROUS SEXUAL OFFENDERS
CRIMINAL LAW - PARTICULAR OFFENCES - OFFENCES AGAINST THE PERSON - SEXUAL OFFENCES
Appeal against an indefinite detention order, pursuant to s 57(7) of the Sentencing Act 2017 (SA).
The appellant was convicted of three counts of rape, two counts of indecent assault, one count of assault causing harm, and two counts of aggravated criminal trespass in a place of residence. On his eventual appeal, he was sentenced to a term of 11 years’ imprisonment, with a non-parole period of five years and six months.
The appellant was not granted parole when he became eligible. Prior to his head sentence expiring, on the application of the Attorney-General, the primary judge had made an interim detention order, pursuant to s 57(5) of the Act. Subsequently, having found that the appellant was unwilling to control his sexual instincts for the purposes of s 57(1) of the Act, the judge made an order detaining the applicant until further order, pursuant to s 57(7) of that Act. He dismissed the Attorney-General’s application that, in the alternative, the appellant be made subject to an extended supervision order, pursuant to s 7 of the Criminal Law (High Risk Offenders) Act 2015 (SA).
The issues raised on this appeal are whether:
●the judge’s finding that the appellant was unwilling to control his sexual instincts was affected by error (Grounds 1-3);
● in any event, the judge erred in the exercise of his discretion (Grounds 4-5); and
●the judge erred in finding that the appellant had committed rapes for which he had not been charged, without making those findings beyond reasonable doubt (Ground 6).
Held (by the Court), dismissing the appeal:
1.It was open to the judge to give weight to the psychiatrists’ evidence with respect to the appellant’s ‘unwillingness’ to control his sexual instincts. The judge stepped through all of the evidence at length and in detail, and there was ample evidence to support his conclusions. The finding that the appellant was unwilling to control his sexual instincts was not affected by error.
2.The judge was plainly alive to the separate discretions arising under the different Acts, and to the enlivening of the discretion to make an extended supervision order. His conclusion as to the exercise of his discretion was premised squarely on his findings about the gravity of the risk that the appellant poses to women in the community. That conclusion was open and was not attended by error.
3.When considering whether to make an order under s 57(7), it will be necessary to find facts, in addition to the facts the subject…
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- AGLC
- Driver v Attorney-General (SA) [2022] SASCA 13
- Case
- [2022] SASCA 13
- Decision Date
CaseChat Overview and Summary
The legal issues before the Court were whether the primary judge erred in finding that the appellant was unwilling to control his sexual instincts, whether the judge erred in the exercise of his discretion to make an extended supervision order, and whether the judge erred in finding that the appellant had committed rapes for which he had not been charged, without making those findings beyond reasonable doubt. The appellant argued that the evidence was insufficient to support the conclusion of unwillingness to control his sexual instincts, particularly given the time elapsed since the offending and his participation in a sexual behaviour clinic program.
The Court held that it was open to the primary judge to give weight to the psychiatrists’ evidence regarding the appellant’s unwillingness to control his sexual instincts, finding ample evidence to support his conclusions. The judge was also found to be alive to the separate discretions under the relevant Acts and correctly exercised his discretion to make an extended supervision order, premising this decision squarely on the gravity of the risk the appellant posed to women. The Court clarified that when considering an order under s 57(7), facts relevant to a person’s unwillingness and the appropriateness of an order must be found on the civil standard, and the judge’s finding of uncharged rapes was based on the appellant’s admissions, not a finding of criminal guilt.
The appeal was dismissed.
Orders
Orders of the court
Held (by the Court), dismissing the appeal:
1. It was open to the judge to give weight to the psychiatrists’ evidence with respect to the appellant’s ‘unwillingness’ to control his sexual instincts. The judge stepped through all of the evidence at length and in detail, and there was ample evidence to support his conclusions. The finding that the appellant was unwilling to control his sexual instincts was not affected by error.
2. The judge was plainly alive to the separate discretions arising under the different Acts, and to the enlivening of the discretion to make an extended supervision order. His conclusion as to the exercise of his discretion was premised squarely on his findings about the gravity of the risk that the appellant poses to women in the community. That conclusion was open and was not attended by error.
3. When considering whether to make an order under s 57(7), it will be necessary to find facts, in addition to the facts the subject of the index offending, that are relevant to the questions of the person’s ‘unwillingness’ and the ‘appropriateness’ of an order. Those questions require determination on the civil standard. In expressing his finding that the appellant had committed rapes for which he had not been charged, the judge did not purport to make a finding of criminal guilt. He did no more than accept the truth of the appellant’s admissions, at the level of abstraction at which they were made.
Background
Background to the litigation
Evidence
Evidence Before The Court
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
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