JE v R [2019] NSWCCA 225

JE v R [2019] NSWCCA 225

Disparity error occurred because the aggregate sentence imposed on the applicant was unexplained and not justified given the difference in indicated sentences and respective culpability. The applicant’s role was less serious than NA’s, and the aggregate sentence should be adjusted to reflect appropriate parity.

Parties
Applicant: JE; Respondent Crown: Regina
Jurisdiction
Australia
Judgment Date
27 September 2019
Procedural Posture
Criminal Sentence Appeal / Appeal From District Court Sentence
Outcome
Leave to appeal granted; appeal allowed; sentence quashed; applicant re-sentenced.
Legal Topics
Sentence Appeal, Aggravated Sexual Assault in Company, Aggravated Indecent Assault, Produce Child Abuse Material, Parity Principle, Culpability and Criminal Responsibility

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Parties

JE

Applicant

Regina

Respondent Crown

Procedural Posture

Criminal Sentence Appeal / Appeal From District Court Sentence

  1. 1 Whether there was unjustified disparity in sentences imposed between co-offenders
  2. 2 Assessment of moral culpability
  3. 3 Appropriateness of aggregate sentence

Ratio Decidendi

Disparity error occurred because the aggregate sentence imposed on the applicant was unexplained and not justified given the difference in indicated sentences and respective culpability. The applicant’s role was less serious than NA’s, and the aggregate sentence should be adjusted to reflect appropriate parity.

Court Disposition

Leave to appeal granted; appeal allowed; sentence quashed; applicant re-sentenced.

Orders

  • Leave to appeal is granted.
  • The appeal is allowed.