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[2004] VSC 218
Supreme Court of Victoria
2004-06-16
WARREN, CJ
Original judgment source is linked above.
[2004] VSC 218
CONFISCATION ACT 1997 - Section 32 - Cultivation of a narcotic plant. PROPERTY - Tainted property - Forfeiture - Undue hardship.
(a) that the jurisdiction arose by virtue of the defendant being found guilty at Sunshine Magistrates' Court on 15 October 2003 of the offence of "cultivate a narcotic plant cannabis" that being a forfeiture offence under the Act, hereafter referred to as "the conviction";
(b) that the grounds of the application were that the defendant had been found guilty of a forfeiture offence;
(c) that the subject property was "tainted property" within the meaning of the Act;
(d) that the application for forfeiture was made within time, that is, before the expiration of the "relevant period" under the Act; and
(e) that no previous application had been made under s.32(1) of the Act in relation to the conviction.
"In considering hardship, it is necessary to bear in mind that, of necessity, in achieving its object, the Act will cause a measure of hardship in the deprivation of property. Indeed that is its intention. ... The provision for relief [under the Act] must not be so interpreted as to frustrate the achieving of the purpose of Parliament in enacting the exceptional provisions of that Act. Something more than ordinary hardship in the operation of the Act is therefore meant."
* the nature of the offender's interest in the property;
* the value of the drugs involved or the size of the crop;
* whether the property was acquired with the proceeds of the sale of drugs;
* the extent to which the property is connected with the commission of the offence;
* the fact that the forfeiture is intended as a deterrent; and
"...the value of the subject property, the nature and gravity of the offence, the use made of the property, the degree of the offender's involvement, the offender's antecedents, the value of any other property confiscated and the penalty imposed, the nature of the offender's interest in the property, the value of the drugs involved or the size of the crop, whether the property was acquired with the proceeds of the sale of drugs, the utility of the property to the offender, the length of ownership of the property, the extent to which the property was connected with the commission of the offence, the fact that forfeiture is intended as a deterrent, the interest of innocent parties in the property and the extent (if any) to which the retention of the property might bear on the offender's rehabilitation."
[1] (1989) 44 A Crim R 63 (per Kirby P as he then was) at 66 - 67.
[2] (1993) 70 A Crim R 252 at 258.
[4] (1991) 53 A Crim R 166 at 175 - 179.
DPP
Cong Quan Tran [2004] VSC 218