District Court
New South Wales
Medium Neutral Citation: R v JH (no 2) [2024] NSWDC 56 Hearing dates: 1 December 2023
22 February 2024Date of orders: 22 February 2024 Decision date: 22 February 2024 Jurisdiction: Criminal Before: Newlinds SC DCJ Decision: See paragraphs [68] – [71]
Catchwords: CRIMINAL LAW – Sentence – Indecent assault – Special Hearing – Penalty pursuant to s59(1) Mental Health and Cognitive Impairment Act 2020 NSW – Offender suffering from Alzheimer disease causing dementia – Proper construction of s65(2) “may make orders”, “place of detention” – Court has power to order detention at nursing home facility.
Legislation Cited: Crimes Act
Crimes (Sentencing Procedure) Act 1999
Mental Health and Cognitive Impairment Forensic Provisions Act 2020 NSW.
Cases Cited: DPP (Cth) vDeLaRosa [2010] 79 NSWLR 1
Moylerv R [2021] NSWCCA 73
MuldrockvR [2011] 244 CLR 120
RvAB [2015] NSWCCA 57
R v JH 2023 NSWDC 391
RvMailes [2004] 62 NSWLR 181
RvWilson [2019] NSWSC 529
Category: Sentence Parties: The Crown
JHRepresentation: Counsel:
Solicitors:
Mr Triscari – The Crown
Mr Tyler Scott – The Defendant
The Director of Public Prosecutions – The Crown
Karim Criminal Defence Lawyers – The defendant
File Number(s): 2021/283176 Publication restriction: There is to be no publication of the name of the complainant or of any material which may tend to identify the complainant.
Judgment
INTRODUCTION
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This is a tragic case.
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On 29 December 2023 following a special hearing on 29 August 2023 I found, on the limited evidence available that the defendant had committed the offences he was charged with on counts 1, 2, 3 and 5 of the indictment dated 9 September 2022 being four counts of indecent assault on a person under the age of 16 years. (R v JH 2023 NSWDC 391)
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The victim is the defendant’s granddaughter. At the time of offending she was between seven and eight years old, and the defendant was about 85 years old. He was found not guilty in relation to count 4, count 5 was in the alternative to count 4.
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I thus entered verdicts to that effect pursuant to s 59(1)(c) of the Mental Health and Cognitive Impairment Forensic Provisions Act 2020 NSW.
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It now falls to me to “sentence” the defendant although this is to misstate the process. The defendant is before me for penalty pursuant to s 63 of the Act.
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I am required to:
First, determine whether the Court would have imposed a sentence of imprisonment for the offence if the special hearing had been an ordinary trial of criminal proceedings and the defendant had been fit to be tried for the offence.
Second, if I determine that a sentence of imprisonment would have been imposed in those circumstances to set a “limiting term” being my best estimate of the sentence the Court would have imposed on the defendant in those circumstances (section 63(2)).
Third, and this is in the alternative to 2, if I…
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- AGLC
- R v JH (no 2) [2024] NSWDC 56
- Case
- [2024] NSWDC 56
- Decision Date
CaseChat Overview and Summary
The primary legal issue was the interpretation of sections 59(1) and 65(2) of the Act. The court needed to determine whether the phrase "may make orders" in section 65(2) allowed for a nursing home placement and whether the term "place of detention" in section 59(1) included nursing homes. The court considered the purpose of the Act, which was to provide a humane and therapeutic environment for offenders with mental health issues or cognitive impairments.
The court held that section 65(2) did confer the necessary authority to make orders for JH's detention in a nursing home, aligning with the Act's objectives. It also concluded that the term "place of detention" was broad enough to encompass nursing homes. The court emphasised the importance of considering the offender's needs and the potential benefits of a nursing home environment in achieving the aims of the Act. Consequently, the court ordered JH's detention at an appropriate nursing home facility, taking into account his medical condition and the need for specialised care.
The court's final orders included JH's detention at a nursing home facility, with specific conditions to ensure his safety and well-being, as well as the safety of others. The orders also included provisions for regular medical assessments and reviews of JH's placement to ensure it remained appropriate.
Orders
Orders of the court
See paragraphs [68] – [71]
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
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