Small v R [2018] NSWCCA 290

Small v R [2018] NSWCCA 290

The sentencing judge took account of the applicant's quasi-custody in sentencing but was not required to backdate the sentence or quantify a specific discount. There was no error in this approach as the allowance for quasi-custody is discretionary, and there is no authority requiring mathematical quantification or backdating. The appeal fails as no miscarriage of justice has occurred.

Jurisdiction
Australia
Judgment Date
14 December 2018
Procedural Posture
Criminal Sentence Appeal / Court of Criminal Appeal Decision on Application for Leave and Appeal
Outcome
Leave to appeal allowed. Appeal dismissed.
Legal Topics
['sentence Appeal' 'quasi Custody Credit' 'supply Prohibited Drug' 'rehabilitation' 'pre Sentence Detention']

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Procedural Posture

Criminal Sentence Appeal / Court of Criminal Appeal Decision on Application for Leave and Appeal

  1. 1 ['Whether sentencing judge erred by failing to give proper credit for time spent in quasi-custody' 'Whether the sentence should have been backdated to reflect quasi-custody']

Ratio Decidendi

The sentencing judge took account of the applicant's quasi-custody in sentencing but was not required to backdate the sentence or quantify a specific discount. There was no error in this approach as the allowance for quasi-custody is discretionary, and there is no authority requiring mathematical quantification or backdating. The appeal fails as no miscarriage of justice has occurred.

Court Disposition

Leave to appeal allowed. Appeal dismissed.

Orders

  • ['Leave to appeal allowed.' 'The appeal is dismissed.']