HIGH COURT OF AUSTRALIA
FRENCH CJ,
HAYNE, BELL, GAGELER AND KEANE JJANDREW O'GRADY APPELLANT
AND
THE QUEEN RESPONDENT
O'Grady v The Queen
[2014] HCA 38
9 October 2014
S114/2014
ORDER
1.Appeal allowed.
2.Set aside the order of the Court of Criminal Appeal of the Supreme Court of New South Wales made on 18 November 2013.
3.Remit the application dated 27 June 2013 to the Court of Criminal Appeal for determination.
On appeal from the Supreme Court of New South Wales
Representation
T A Game SC with G A Bashir for the appellant (instructed by Legal Aid NSW)
J H Pickering SC with T L Smith for the respondent (instructed by Solicitor for Public Prosecutions (NSW))
Notice: This copy of the Court's Reasons for Judgment is subject to formal revision prior to publication in the Commonwealth Law Reports.
CATCHWORDS
O'Grady v The Queen
Criminal law – Appeal – Application to extend time within which to apply for leave to appeal against sentence – Principles to be applied in determining whether extension of time should be granted – Whether applicant required to demonstrate that refusal of application would occasion substantial injustice – Relevance of principle of finality – Relevance of prospect of success should extension be granted – Whether extension of time should be granted.
Words and phrases – "Abdul test", "principle of finality", "substantial injustice".
Criminal Appeal Act 1912 (NSW), s 10(1)(b).
Criminal Appeal Rules (NSW), rr 3A, 3B.
FRENCH CJ, HAYNE, BELL, GAGELER AND KEANE JJ. This appeal was heard together with the appeal of Phillip Charles Kentwell[1]. It raises the same issue as to the correctness of the principles applied by the Court of Criminal Appeal of the Supreme Court of New South Wales in the determination of applications to extend the time in which to apply for leave to appeal against a sentence on the ground of "Muldrock error"[2]. These reasons are to be read with the reasons in Kentwell.
The appellant was convicted following a trial in the District Court of New South Wales (Murrell DCJ and a jury) of an offence of specially aggravated breaking and entering[3]. The offence is subject to a maximum penalty of 25 years' imprisonment and a standard non-parole period of seven years' imprisonment[4]. On 17 September 2010, Murrell DCJ sentenced the appellant to a non-parole period of five years and six months' imprisonment with a balance of term of three years and six months. The appellant will be eligible for release on parole on 22 November 2015.
[3]Crimes Act 1900 (NSW), s 112(3).
[4]Crimes (Sentencing Procedure) Act 1999 (NSW), Pt 4, Div 1A, Table, Item No 13.
Murrell DCJ (as her Honour then was) found that the offence was in the middle of the range of objective seriousness for offences of this description. Her Honour said that the sentence…
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- AGLC
- O'Grady v The Queen [2014] HCA 38
- Case
- [2014] HCA 38
- Decision Date
CaseChat Overview and Summary
The central legal issue before the High Court was the principles to be applied by an appellate court when determining whether to grant an extension of time for an application for leave to appeal against sentence. Specifically, the court had to consider the relevance of the principle of finality in criminal proceedings, the necessity for the applicant to demonstrate that refusal of the extension would occasion a substantial injustice, and the weight to be given to the prospect of success on the substantive appeal should an extension be granted.
The High Court allowed the appeal, setting aside the order of the Court of Criminal Appeal. The Court reasoned that the "Abdul test" (referring to principles established in *Abdul v The Queen* (2011) 243 CLR 30) required a careful balancing of competing considerations, including the principle of finality and the need to avoid substantial injustice. The Court found that the Court of Criminal Appeal had not adequately applied these principles in refusing the extension of time. Consequently, the High Court remitted O'Grady's application for leave to appeal against sentence back to the Court of Criminal Appeal for determination according to the correct legal principles.
Orders
Orders of the court
1. Appeal allowed.
2. Set aside the order of the Court of Criminal Appeal of the Supreme Court of New South Wales made on 18 November 2013.
3. Remit the application dated 27 June 2013 to the Court of Criminal Appeal for determination.
Background
Background to the litigation
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Evidence
Evidence Before The Court
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Decision
Reasons for decision
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Ratio Decidendi
Legal Principle Established
Established by: FRENCH CJ, HAYNE, BELL, GAGELER AND KEANE JJ
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