SUPREME COURT OF SOUTH AUSTRALIA
(Court of Criminal Appeal)
R v SAUNDERS
[2011] SASCFC 37
Judgment of The Court of Criminal Appeal
(The Honourable Justice Gray, The Honourable Justice Vanstone and The Honourable Justice White)
29 April 2011
CRIMINAL LAW - APPEAL AND NEW TRIAL - APPEAL AGAINST SENTENCE - APPEALS BY CROWN - PRINCIPLES APPLIED BY APPELLATE COURT TO CROWN APPEALS
CRIMINAL LAW - SENTENCE - RELEVANT FACTORS - TIME SPENT IN CUSTODY
CRIMINAL LAW - SENTENCE - SENTENCING ORDERS - ORDERS AND DECLARATIONS RELATING TO SERIOUS OR VIOLENT OFFENDERS OR DANGEROUS SEXUAL OFFENDERS - SERIOUS OR VIOLENT OFFENDER
Permission to appeal against sentence by the Director of Public Prosecutions - defendant pleaded guilty to one count of aggravated robbery and two counts of aggravated causing serious harm with intent to cause serious harm - where Judge declared the defendant a serious repeat offender - where defendant was sentenced to a head sentence of 12 years’ imprisonment which was reduced by two years and 17 days on account of time spent in custody - where unexpired balance of sentence for which defendant had been on parole, taken into account - where Judge fixed a non-parole period of eight years - whether Judge proceeded under a misapprehension of fact as to the time the defendant had spent in custody - whether Judge misapplied the statutory provisions applicable to sentencing a serious repeat offender.
Principles regarding applications by the Director of Public Prosecutions for permission to appeal against sentence discussed - Court’s powers and duties on appeal against sentence discussed.
Held: Permission to appeal against sentence granted - appeal allowed - sentence imposed by Judge set aside - defendant resentenced.
Criminal Law Consolidation Act 1935 (SA) s 23(1), s 137(1), s 340, s 352 and s 353; Criminal Law (Sentencing) Act 1988 (SA) s 9A, s 18A, s 20A, s 20B, s 20C, s 23, s 32 and s 32A; Sentencing Act 1995 (WA) s 98; Habitual Criminals Act 1957 (NSW) s 4(1) and s 6; Correctional Services Act 1982 (SA) s 74 and s 75; Statutes Amendment (Recidivist Young Offenders and Youth Parole Board) Act 2009 (SA) s 10, referred to.
Malvaso v The Queen (1989) 168 CLR 227; Everett v The Queen (1994) 181 CLR 295; R v Osenkowski (1982) 30 SASR 212; R v Nemer (2003) 87 SASR 168; Dinsdale v The Queen (2000) 202 CLR 321; R v Marikar [2010] SASCFC 36; R v Drewett (1983) 35 SASR 344; R v Mangelsdorf (1995) 66 SASR 60; R v Elliott (2001) 121 A Crim R 254; R v Ivic [2006] SASC 8; R v Robinson [2004] SASC 189; R v Meers (1998) 101 A Crim R 329; Minister for Employment and Workplace Relations v Gribbles Radiology Pty Ltd (2005) 222 CLR 194; Palgo Holdings Pty Ltd v Gowans (2005) 221 CLR 249; K-Generation Pty Ltd v Liquor Licensing Court (2009) 237 CLR 501; Project Blue…
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- AGLC
- R v Saunders [2011] SASCFC 37
- Case
- [2011] SASCFC 37
- Decision Date
CaseChat Overview and Summary
The court was required to determine whether the sentencing judge erred in the computation of the time the respondent had spent in custody and whether the judge had correctly applied the provisions of section 20B of the Criminal Law (Sentencing) Act 1988, which mandates that the non-parole period for a serious repeat offender must be at least four-fifths of the head sentence. The court also considered whether the head sentence and the non-parole period were manifestly inadequate given the gravity of the offences and the respondent's prior criminal history.
The court found that the sentencing judge had made an error in calculating the time in custody, to the respondent's favour, by approximately two months and 23 days. More significantly, the court determined that the judge had plainly erred in believing they retained a discretion not to fix a non-parole period of at least four-fifths of the head sentence, despite the declaration of the respondent as a serious repeat offender. This misapplication of section 20B led to a non-parole period that the court considered manifestly inadequate. The court also found the head sentence to be too low, notwithstanding the pleas of guilty and the discount given.
Consequently, the court granted the Director permission to appeal, allowed the appeal, and set aside the original sentence. The court resentenced the respondent to a total term of imprisonment of 13 years and two months, to be served cumulatively on the unexpired balance of his previous sentence, resulting in a total period of imprisonment of 15 years, nine months, and 20 days. A non-parole period of 11 years and 10 months was fixed, commencing from the date of the original sentencing.
Orders
Orders of the court
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Background
Background to the litigation
Evidence
Evidence Before The Court
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Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
Established by: WHITE J
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