SUPREME COURT OF SOUTH AUSTRALIA
(Court of Appeal: Criminal)
R v GRUNDY
[2021] SASCA 4
Judgment of the Court of Appeal
(The Honourable President Kelly, the Honourable Justice Doyle and the Honourable Justice Bleby)
3 March 2021
CRIMINAL LAW - SENTENCE - SENTENCING ORDERS - CUSTODIAL ORDERS - HOME DETENTION ORDERS
CRIMINAL LAW - PARTICULAR OFFENCES - OFFENCES AGAINST PEACE AND PUBLIC ORDER - OFFENSIVE WEAPONS - FIREARMS - POSSESSION
Crown application for permission to appeal against sentence.
The respondent (Mr Grundy) was found guilty of one count of possessing a firearm without a licence, contrary to s 9(1) of the Firearms Act 2015 (SA). As the offence involved a category H firearm, it carried a maximum penalty of $35,000 or imprisonment for seven years, and satisfied the definition of a “serious firearm offence”.
The respondent was sentenced to a term of imprisonment of nine months (reduced from 15 months to reflect time spent in custody and on home detention bail). The sentencing Judge found the respondent to be a suitable candidate for a home detention order, and ordered that the respondent serve his period of imprisonment on home detention pursuant to the discretionary power in s 71 of the Sentencing Act.
The issue sought to be raised by the Director in his proposed appeal is the availability of an order under s 71 that a sentence of imprisonment in respect of a serious firearm offence be served on home detention. Section 70(1)(b)(ii)(D) of the Sentencing Act precludes home detention for a defendant who is being sentenced for an offence in respect of which an Act “expressly prohibits the reduction, mitigation and substitute of penalties for that offence”. The Director contends that the provision in s 51(1)(c) to the effect that the general statutory power under s 25 to reduce, mitigate or substitute penalties does not apply when sentencing serious firearm offenders for serious firearm offences, is sufficient to engage s 70(1)(b)(ii)(D) and hence preclude the availability of a home detention order.
Held, per Doyle JA (Kelly P and Bleby JA agreeing), dismissing the application for permission to appeal:
1. The disapplication of s 25 of the Sentencing Act by s 51(1)(c) merely prevents the utilisation of the general power to reduce, mitigate or substitute, and is not an express prohibition against the reduction, mitigation or substitution of penalties or sentences. As such, the disqualification of s 25 by s 51(1)(c) does not trigger the preclusionary effect of s 70(1)(b)(ii)(D), and leaves open and available the court’s discretionary power under s 71 to make a home detention order.
Sentencing Act 2017 (SA) ss 25, 49, 50, 51, 69, 70, 71, 79, 81, 96; Firearms Act 2015 (SA) ss 9(1), 9(4); Criminal Law (Sentencing) Act 1988 (SA) s 18; Criminal Law Consolidation Act 1935 (SA) ss 13, 19A, 19AB, 19AC, 19AD, 29, 86A; Road Traffic Act 1961 (SA) ss 43, 45, 47, 47B, 47BA, 47E, 47EAA, 47I, referred to.
R v Dell (2016) 126 SASR 571; Police v Berzins (2011)…
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- AGLC
- R v Grundy [2021] SASCA 4
- Case
- [2021] SASCA 4
- Decision Date
CaseChat Overview and Summary
The central legal issue before the court was whether section 70(1)(b)(ii)(D) of the *Sentencing Act 2017* (SA) operated to prohibit the making of a home detention order when sentencing an offender for a serious firearm offence. This required an interpretation of the interplay between section 70(1)(b)(ii)(D) and section 51(1)(c) of the Act, which deals with the narrowing of sentencing options for serious firearm offences.
The court, per Doyle JA, dismissed the application for permission to appeal. It reasoned that the disapplication of section 25 of the *Sentencing Act* by section 51(1)(c) was not an express prohibition against the reduction, mitigation, or substitution of penalties. Instead, it merely prevented the utilisation of the general power under section 25. Consequently, the disqualification of section 25 by section 51(1)(c) did not trigger the preclusionary effect of section 70(1)(b)(ii)(D). The court held that this left open the court's discretionary power under section 71 to make a home detention order, as such an order is made under specific powers rather than the general power under section 25. The court also noted that any real ambiguity in a penal provision should be resolved in favour of the accused.
The Director's application for permission to appeal was dismissed.
Orders
Orders of the court
Held, per Doyle JA (Kelly P and Bleby JA agreeing), dismissing the application for permission to appeal:
1. The disapplication of s 25 of the Sentencing Act by s 51(1)(c) merely prevents the utilisation of the general power to reduce, mitigate or substitute, and is not an express prohibition against the reduction, mitigation or substitution of penalties or sentences. As such, the disqualification of s 25 by s 51(1)(c) does not trigger the preclusionary effect of s 70(1)(b)(ii)(D), and leaves open and available the court’s discretionary power under s 71 to make a home detention order.
Background
Background to the litigation
Evidence
Evidence Before The Court
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Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
To the extent that there remains some ambiguity in the construction of, and interaction between, ss 70(1)(b)(ii)(D) and 51(1)(c) of the Sentencing Act, authority supports its resolution in favour of the respondent. As Kiefel CJ and Keane J recently observed in the analogous context of construing offence provisions in R v A2; R v Magennis; R v Vaziri:[12]A statutory offence provision is to be construed by reference to the ordinary rules of construction. The old rule, that statutes creating offences should be strictly construed, has lost much of its importance. It is nevertheless accepted that offence provisions may have serious consequences. This suggests the need for caution in accepting any “loose” construction of an offence provision. The language of a penal provision should not be unduly stretched or extended. Any real ambiguity as to meaning is to be resolved in favour of an accused. An ambiguity which calls for such resolution is, however, one which persists after the application of the ordinary rules of construction.The operation of the s 51 scheme for the narrowing of sentencing options for serious firearm offending[12] R v A2; R v Magennis; R v Vaziri (2019) 93 ALJR 1106 at [52] (omitting footnotes). I have earlier made some observations in relation to the s 51 scheme for the narrowing of sentencing options in respect of any sentence to be imposed upon a serious firearm offender for a serious firearm offence. I do not consider that the approach I have taken to the issue of statutory construction posed by the Director’s proposed appeal gives rise to any incongruity in the operation of s 51. To the contrary, I consider that it gives effect, in a coherent and practical manner, to Parliament’s obvious intention to narrow the sentencing options available to a court when sentencing a serious firearm offender for a serious firearm offence. By way of overview, s 51(1)(a) requires the imposition of a sentence of imprisonment when that is one of the available sentencing options in the relevant offence provision. It thus precludes the imposition of a fine, even if the offence provision would otherwise have permitted it. By reason of s 51(1)(b), the court is precluded from ordering the suspension of the sentence of imprisonment unless it is appropriate to make a declaration of the type contemplated by s 51(2). In this way, the threshold or test for the suspension of the sentence of imprisonment is higher than would otherwise have been applicable under s 96 (which requires merely the existence of “good reason” to suspend). And by reason of s 51(1)(c), the court is precluded from applying s 25 so as to reduce or substitute the applicable sentence by, for example, imposing a fine or community service order. If the court does not suspend the sentence of imprisonment, then in my view that leaves open the possibility of a home detention order or intensive correction order. In making any such order, the court would be making an order under its specific powers in that respect under ss 71 or 81, rather than the (precluded) general power to reduce, add or substitute under s 25. Further, given that the Sentencing Act treats home detention orders and intensive correction orders as sentences of imprisonment, albeit to be served in the community, the making of a home detention or intensive correction order would not offend the s 51(1)(a) prescription that the court impose a sentence of imprisonment.