The State of Western Australia v Brown [No 11]

In this case, the State of Western Australia applied for the rescission of a supervision order and the making of a continuing detention order in relation to the respondent, Alwyn Wayne Brown, under the High Risk Serious Offenders Act 2020 (WA). The application was made due to the respondent's contravention of the conditions of the supervision order and subsequent charges of serious offences against children. The court considered the evidence presented, including expert opinions, the respondent's history of offending, and the risk he posed to the community.

The court found that the respondent had a significant history of sexual offending against young female children and continued to have a paedophilic interest. Despite his willingness to recommence antilibidinal treatment, the court was not satisfied that the respondent would substantially comply with the standard conditions of a supervision order, particularly the condition that he not commit a serious offence during the period of the order. The court concluded that releasing the respondent on a supervision order would not ensure adequate protection of the community.

As a result, the court rescinded the supervision order and made a continuing detention order in relation to the respondent. The court also provided recommendations for the respondent to improve his chances of being released on a supervision order in the future, including acknowledging his sexual interest in young female children, recommencing antilibidinal treatment, and meaningfully engaging in psychological counselling.