SUPREME COURT OF SOUTH AUSTRALIA
(Court of Appeal: Criminal)
MORTON (A PSEUDONYM) v THE KING
[2025] SASCA 29
Judgment of the Court of Appeal
(The Honourable Chief Justice Kourakis, the Honourable Justice S Doyle and the Honourable Justice David)
20 March 2025
CRIMINAL LAW - APPEAL AND NEW TRIAL - APPEAL AGAINST SENTENCE
CRIMINAL LAW - PARTICULAR OFFENCES - OFFENCES AGAINST THE PERSON - SEXUAL OFFENCES - MAINTAINING SEXUAL RELATIONSHIP WITH CHILD AND PERSISTENT SEXUAL ABUSE OF CHILD
CRIMINAL LAW - APPEAL AND NEW TRIAL - VERDICT UNREASONABLE OR INSUPPORTABLE HAVING REGARD TO EVIDENCE - APPEAL DISMISSED
STATUTES - ACTS OF PARLIAMENT - VALIDITY OF LEGISLATION GENERALLY
CRIMINAL LAW - GENERAL MATTERS - OTHER GENERAL MATTERS - CONSTRUCTION OF CRIMINAL CODES
CRIMINAL LAW - PARTICULAR OFFENCES - OFFENCES AGAINST THE PERSON - SEXUAL OFFENCES - SENTENCE - PARTICULAR CASES - MAINTAINING SEXUAL RELATIONSHIP WITH CHILD AND PERSISTENT SEXUAL ABUSE OF CHILD
APPEAL AND NEW TRIAL - NEW TRIAL - IN GENERAL AND PARTICULAR GROUNDS - IN GENERAL - MISCARRIAGE OF JUSTICE - CIRCUMSTANCES NOT INVOLVING MISCARRIAGE
CRIMINAL LAW - EVIDENCE - CHARACTER AND PRIOR CONVICTIONS - EVIDENCE OF GOOD CHARACTER
This is an appeal against conviction and sentence.
The appellant was convicted of one count of sexual abuse of a child, C, by a trial by jury on 3 February 2022. The presiding Judge sentenced the applicant to 10 years imprisonment with a non-parole period of five years. This conviction was set aside on appeal and a new trial ordered. The applicant was again convicted in the second trial. The Judge presiding over the second trial sentenced the applicant to 12 years imprisonment with a non-parole period of six years, eight months, and one day.
The appellant was the stepfather of C. C was seven years and four months at the commencement of the period of the alleged sexual abuse, and nine years and two months when that period came to an end.
The particulars of the charge alleged that the appellant incited C to touch his penis on more than one occasion, engaged in unlawful sexual acts in the nature of penetration on more than one occasion; touched C’s genitalia on more than one occasion; caused C to perform an act of fellatio on more than one occasion; and attempted to kiss C on more than one occasion.
The appellant appeals against conviction on the appeal relied on the following grounds:
1. The Judge erred in ruling that he would give permission to the prosecution to adduce evidence of his bad character if he were to lead evidence of his good character;
2. A miscarriage of justice arose from the prosecutor inviting the jury to speculate that the victim had no reason to make up the allegations;
3. The verdict was unreasonable, having regard to inconsistencies in the evidence;
4. Section 50(4)(c) of the Criminal Law Consolidation Act 1935 (SA) (‘the Act’) is unconstitutional on the ground that, by allowing for minority verdicts, it impermissibly interferes with the institutional…
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- AGLC
- Morton (a pseudonym) v The King [2025] SASCA 29
- Case
- [2025] SASCA 29
- Decision Date
CaseChat Overview and Summary
The primary legal issue before the Court was whether a sentencing judge, on a retrial after a successful appeal against a previous conviction, must be satisfied that the original sentence was manifestly inadequate before imposing a longer term of imprisonment. The Court also considered the nature and status of the "ceiling principle" in the context of a fresh sentencing discretion.
The Court reasoned that a sentence formerly imposed but subsequently quashed is a relevant consideration in the fresh exercise of sentencing discretion but does not constrain it. Conditioning the proper exercise of discretion on a threshold of manifest inadequacy for appellate review is inconsistent with the statutory conferral of sentencing power. The Court affirmed that while the "ceiling principle" dictates that an offender should not be worse off as a result of a successful appeal, it does not prevent a higher sentence on retrial if there are good reasons, such as the original sentence being manifestly inadequate or materially different facts emerging. The Court concluded that the sentencing judge had not erred in principle by imposing a longer term of imprisonment than that previously imposed.
Permission to appeal against sentence was granted, but the appeal itself was dismissed. The appeal against conviction was also dismissed.
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
In McL v The Queen, Gleeson CJ, Gaudron and Callinan JJ observed:[54]… in the absence of countervailing considerations, the sentences imposed following the first trial should be regarded as the upper limit of the sentence to be imposed following the second trial, otherwise an offender will be seen to have been worse off as a result of having brought a successful appeal against a conviction. The weight to be given to that consideration depends, of course, upon the circumstances of the individual case.(Emphasis added)[54] (2000) 203 CLR 452, 459 [23]. Justices McHugh, Gummow and Hayne took the matter somewhat further, observing that:[55]… Ordinarily but not invariably, a successful appellant should not receive a longer sentence after conviction on a re-trial than he or she received at the original trial. If the sentencing judge at the re-trial thinks that the original sentence was manifestly inadequate, it is open to that judge in the exercise of the sentencing discretion to give a sentence higher than that imposed on the first occasion. But an exercise of discretion by a sentencing judge that increases the original sentence given to the accused is necessarily rare.[55] Ibid 475-6 [72]. That case concerned the substitution of sentence, formerly imposed by the County Court of Victoria, by the Court of Appeal of Victoria, pursuant to s 569(1) of the Crimes Act 1958 (Vic). Respectfully, the assimilation of the ‘ceiling principle’ by Gleeson CJ, Gaudron and Callinan JJ as one of the relevant sentencing considerations on a resentencing, and not as a superimposed threshold before the discretion can be exercised differently, is more consistent with the nature of the statutory sentencing power. Such difference as there may be in practice between the two approaches can be seen as a matter of the weight which is attached to the ‘ceiling’ consideration. In DWG v State of Western Australia,[56] after an extensive survey of the case law on the ‘ceiling principle’, Buss P distilled a number of propositions regarding the interaction of that principle with the fresh exercise of the sentencing discretion on a retrial:[57][56] [2023] WASCA 133 (‘DWG v State of Western Australia’).[57] Ibid [60]. In my opinion, a number of propositions, including the following, may be distilled from the case law:(a)A judge, who is sentencing an offender after a retrial following the offender’s successful appeal against conviction at the original trial, is not ‘resentencing’ the offender, but exercising an independent sentencing discretion in relation to the offences of which the offender has been convicted at the retrial.(b)The so-called principle of restraint or ceiling principle describes a consideration which a judge, who is sentencing an offender after a retrial following the offender’s successful appeal against conviction at the original trial, should take into account.(c)The proper application of the so-called principle of restraint or ceiling principle requires a consideration by the judge at the retrial of all the components of the original sentence including (in the case of multiple offences) the total effective sentence, the individual sentences, the orders for cumulacy or concurrency, any backdating of the total effective sentence and any parole eligibility order.(d)Ordinarily, absent countervailing considerations, the sentences imposed by the judge at the original trial should be regarded as the upper limit of the sentences to be imposed following the retrial, so that the offender will not be seen to have been in a worse position as a consequence of the offender’s successful appeal against conviction at the original trial.(e)However, the judge at the retrial may impose sentences that are higher than those imposed by the judge at the original trial for good reason; for example, if the sentences imposed by the judge following the original trial were manifestly inadequate or if the facts established at the time of sentencing following the retrial are materially different from those that were established at the time of sentencing following the original trial.(f)An exercise of discretion by the judge at the retrial that increases the original sentence given to the offender should be rare … Where an exercise of discretion by the judge at the retrial increases the original sentence, good reason for the increase should be identified by the judge.(g)Where an offender is convicted at the retrial of fewer offences or less serious offences than at the original trial, the so-called principle of restraint or ceiling principle applies … The manner in which the totality principle was applied at the original sentencing may be significant in the determination of the sentencing outcome following the retrial … The sentencing outcome following the retrial must be an appropriate reflection of the objective gravity of the overall offences, having regard to all relevant facts and circumstances and all relevant sentencing factors. The so-called principle of restraint or ceiling principle, as modified in the manner and to the extent explained and illustrated in those cases, does not mandate that the judge at the retrial make a proportionate reduction in the total effective sentence imposed by the judge at the original trial.(Citations omitted)