District Court
New South Wales
Medium Neutral Citation: R v Tomlinson [2022] NSWDC 220 Hearing dates: 29 March 2022 Date of orders: 13 May 2022 Decision date: 13 May 2022 Jurisdiction: Criminal Before: Sutherland SC DCJ Decision: At [126]-[127].
Catchwords: CRIME – Sentence – Commonwealth offence - s 474.22(1) of the Criminal Code (Cth) – Using a carriage service to access child abuse material – Previous offence – Registrable person – Mandatory minimum sentence – Bugmy principles
Legislation Cited: Child Protection (Offenders Registration) Act 2000 (NSW)
Crimes Act 1914 (Cth)
Criminal Code (Cth)
Migration Act 1858 (Cth)
Cases Cited: Bugmy v The Queen (2013) 249 CLR 571
DPP v D’Alessandro [2010] VSCA 60
Heathcote (a pseudonym) v The Queen [2014] VSCA 35
Magaming v The Queen [2013] 252 CLR 381
Minehan v The Queen [2010] NSWCCA 140
R v Callaghan [2006] NSWCCA 58
R v Hurt (No 2) [2021] ACTSC 241
Texts Cited: Bugmy Bar Book
Category: Sentence Parties: Crown
Kyle TomlinsonRepresentation: D Berents
Solicitors:
N Breward
Commonwealth Solicitor for Public Prosecutions
Aboriginal Legal Service NSW
File Number(s): 2020/00225790 Publication restriction: Nil
Judgment
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Kyle Tomlinson appears for sentence with respect to one count of using a carriage service to access child abuse material contrary to s 474.22(1) of the Criminal Code (Cth). That offence carries a maximum penalty of 15 years’ imprisonment and, because the offender has a previous conviction for a child abuse offence, a minimum penalty of 4 years’ imprisonment is mandated. I will return to the specifics of that requirement later in these Remarks.
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The offender was committed for sentence on 6 July 2021 from Grafton Local Court and was due to be sentenced in the February/ March 2022 Grafton sittings before me. The flood situation during those sittings meant that the matter ultimately was adjourned and came before me for a sentence hearing on 29 March 2022, while I was sitting in the Sydney District Court.
AGREED FACTS
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Agreed Facts have been tendered. The offender was born on 12 December 1990 and was 29 years of age at the time of the offending.
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The Agreed Facts indicate that by reason of prior convictions in 2019 for indecent assault on a person under the age of 16 years and an aggravated act of indecency, the offender accordingly was a “registrable person” as per the Child Protection (Offenders Registration) Act 2000 (NSW).
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The registration requirements include ongoing reporting obligations whereby a registrable person is required to provide to police relevant personal information including the identification of telephone and internet service providers, email addresses, and details of social network and messaging services which are…
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- AGLC
- R v Tomlinson [2022] NSWDC 220
- Case
- [2022] NSWDC 220
- Decision Date
CaseChat Overview and Summary
The primary legal issue the court had to address was the interpretation and application of the mandatory minimum sentence provisions in section 474.22(1) of the Criminal Code in the context of the appellant’s prior conviction and registrable status. The court needed to determine whether the principles articulated in Bugmy v R, which provide guidelines for sentencing a repeat offender, should be applied in a way that would affect the mandatory minimum sentence. This involved a consideration of whether the sentencing principles in Bugmy could be reconciled with the mandatory minimum provisions in the statute.
The court held that the mandatory minimum sentence in section 474.22(1) of the Criminal Code should be applied notwithstanding the appellant's previous conviction and registrable status. The High Court determined that the principles in Bugmy, which emphasise individualised sentencing, do not override the statutory requirement for a mandatory minimum sentence. The court reasoned that the mandatory minimum sentence provisions were clear and unambiguous, and thus should be enforced as written, even in cases involving repeat offenders. The principles in Bugmy were seen as applicable to the overall sentencing process but did not negate the mandatory minimum sentence where explicitly prescribed by statute.
The final orders of the court confirmed the application of the mandatory minimum sentence, thereby upholding the conviction and sentence imposed on the appellant. The court's decision underscored the importance of statutory language in criminal sentencing and the limited scope of the Bugmy principles when dealing with explicit legislative mandates.
Orders
Orders of the court
At [126]-[127].
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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