| IN THE SUPREME COURT OF NEW ZEALAND I TE KŌTI MANA NUI O AOTEAROA |
| SC 44/2023 [2023] NZSC 119 |
| BETWEEN | NGOC HONG TRUONG |
| AND | THE KING |
| Court: | Glazebrook, Williams and Kós JJ |
Counsel: | J N Olsen for Applicant |
Judgment: | 4 September 2023 |
JUDGMENT OF THE COURT
The application for leave to appeal is dismissed.
____________________________________________________________________
REASONS
Background
The applicant, Ms Truong, is a Vietnamese national with permanent residence status in New Zealand. She has two New Zealand-born children who are New Zealand citizens. Along with her husband she pleaded guilty to cultivating cannabis and theft of electricity.[1] She was sentenced to five months’ community detention, eight months’ supervision and ordered to pay reparations in relation to the electricity.[2]
[1]Mr Hoang, the applicant’s husband, is also a Vietnamese national. He was living unlawfully in this country at the time and, after serving a sentence of home detention, was deported to Vietnam.
[2]R v Truong [2019] NZDC 26677 (Judge Bergseng).
Just over three years later she received a letter from Immigration New Zealand. The letter advised that, due to her offending, she was liable to deportation pursuant to s 161(1)(b) of the Immigration Act 2009 and might receive a formal deportation liability notice (DLN). As the name suggests, a DLN would render Ms Truong liable to deportation at the direction of Immigration New Zealand. It appears that Ms Truong would have received her pre-DLN letter sooner but for the fact that she was suffering from significant mental health issues due to the enforced separation from her husband, the fact that she was pregnant at the time and the stress of the criminal proceedings.
On receipt of the letter, Ms Truong brought a convictions and sentence appeal to the Court of Appeal over three years out of time.[3] The Crown did not oppose the application in that Court to bring the appeal out of time, or the admission of affidavits in support of the appeal setting out relevant background.
[3]Truong v R [2023] NZCA 97 (Gilbert, Ellis and Davison JJ).
Ms Truong sought discharge without conviction pursuant to s 106 of the Sentencing Act 2002. The only issue on appeal was whether the applicant’s exposure to the possibility of deportation (a risk not appreciated at the time of her guilty plea) might have rendered the consequences of conviction out of all proportion to the gravity of the offence in terms of s 107 of the Sentencing Act.
Court of Appeal decision
The Court of Appeal found that the risk the applicant might be deported pursuant to s 161(1)(b) of the Immigration Act was not a consequence out of all proportion to the gravity of her offending.[4] The Court came to this view primarily because the Immigration Act has its own procedures for the consideration of the circumstances of a potential deportee both prior to the issue of a DLN and after a notice is given. At the first stage, those at risk of…
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- AGLC
- Truong v The King [2023] NZSC 119
- Case
- [2023] NZSC 119
- Decision Date
CaseChat Overview and Summary
The legal issue before the Supreme Court was whether the Court of Appeal erred in its application of section 107 of the Sentencing Act 2002 when it determined that the risk of deportation did not render the consequences of conviction disproportionate to the gravity of the offence. Truong argued that the Court of Appeal failed to properly apply the'real and appreciable risk' test. The Crown contended that the Court of Appeal correctly applied the test and found that the risk of deportation was not significant enough to meet the statutory requirement. The Supreme Court considered the evidence and concluded that while the Court of Appeal might have reached a different outcome with different facts, it did not misapply the 'real and appreciable risk' test. The court found that the offending was moderately serious, and the risk of deportation, while significant, was not out of proportion to the gravity of the offence given the statutory processes available.
The Supreme Court determined that no issue of principle arose in the case and saw no risk of miscarriage if the application for leave to appeal was dismissed. The Court held that the Court of Appeal correctly found that the risk of deportation was not so significant as to establish that the consequences of conviction were out of all proportion to the gravity of the offence. The Court noted that the Court of Appeal's conclusion that the consequences were not disproportionate was based on factual assessments and the statutory processes in place to consider deportation. As a result, the Supreme Court dismissed the application for leave to appeal.
Orders
Orders of the court
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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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