SUPREME COURT OF SOUTH AUSTRALIA
(Court of Criminal Appeal)
R v HARVEY (No 2)
[2014] SASCFC 106
Judgment of The Court of Criminal Appeal
(The Honourable Chief Justice Kourakis, The Honourable Justice Blue and The Honourable Justice Bampton)
29 September 2014
CRIMINAL LAW - APPEAL AND NEW TRIAL - APPEAL AGAINST SENTENCE - APPEALS BY CROWN
CRIMINAL LAW - PARTICULAR OFFENCES - OFFENCES AGAINST THE PERSON - SEXUAL OFFENCES - SENTENCE
Crown appeal against sentence for sex offending – respondent found guilty of four counts of persistent sexual exploitation of a child following a trial by Judge alone – sentenced to two years’ imprisonment – respondent was already serving sentence of six years’ imprisonment for unlawful sexual intercourse committed in 2010 – sentence was made cumulative upon existing head sentence – non-parole period of three years and three months was fixed – whether the sentence of two years and the consequent non-parole period are manifestly inadequate – respondent in a position of trust – importance of general deterrence and personal deterrence – sentence manifestly inadequate.
Held: Per Bampton J (Kourakis CJ and Blue J agreeing)
1. Permission to appeal granted; appeal allowed;
2. Sentence set aside; respondent resentenced to five years imprisonment cumulative on the head sentence of six years imposed on 9 February 2012;
3. The non-parole period reviewed and extended to six years and six months.
Criminal Law (Sentencing) Act 1988 (SA) s 10(4), s 18A, s 29D, referred to.
Everett v The Queen (1994) 181 CLR 295; MJDH v Director of Public Prosecutions (SA) (2013) 116 SASR 180; R v D (1997) 69 SASR 413; R v Quinn (2012) 114 SASR 354; R v MJJ, R v CJN (2013) 117 SASR 81; R v Lewis (1993) 60 SASR 582; R v Creed (1985) 37 SASR 566; R v McInerney (1986) 42 SASR 111; R v Bonython-Wright (2013) 117 SASR 410, considered.
R v HARVEY (No 2)
[2014] SASCFC 106Court of Criminal Appeal: Kourakis CJ, Blue and Bampton JJ
KOURAKIS CJ: I would allow the appeal and join in the orders proposed by Bampton J for the reasons she has given. I make the following additional observations.
Even though the offending was non-penetrative, it is likely that the sexual connotation of the conduct was, or over time will be, sufficiently understood by the child victims to have a seriously disruptive effect on their psyche, or to at least pose a significant risk of such harm.
Moreover, for the reasons articulated in the judgment of Bampton J, personal and general deterrence demand a substantial term of imprisonment notwithstanding the relatively less severe form of the offending.
BLUE J: I agree with Bampton J.
BAMPTON J: The Director of Public Prosecutions (“the Director”) applies for permission to appeal against a sentence imposed in the District Court. The respondent was found guilty of four counts of persistent sexual exploitation of a child following a trial by Judge alone. He was sentenced…
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- R v Harvey (No 2) [2014] SASCFC 106
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- [2014] SASCFC 106
- Decision Date
CaseChat Overview and Summary
The central legal issue before the court was whether the two-year sentence and the consequent non-parole period were manifestly inadequate, given the nature of the offences and the respondent's position of trust as director of an Out of School Hours Care program. The court was required to consider the importance of general and personal deterrence in sentencing for such offences.
The court reasoned that the sentence imposed failed to adequately reflect the principles of sentencing, particularly the paramount considerations of personal and general deterrence. The offending constituted a gross breach of trust, was committed against four victims over an extended period, and had caused significant community outrage. The court emphasised the insidious effect of such offences on community trust in those responsible for children's care, referencing established legal principles regarding the need for punishment to fit the crime and to mark societal condemnation. The court concluded that the sentence was manifestly inadequate and that the non-parole period, like the head sentence, must be proportionate to the gravity of the crime.
The court granted the Director's application for permission to appeal and allowed the appeal, finding the sentence to be manifestly inadequate.
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