DPP v Sahin [2025] VCC 1730

1. You have also consented to this court hearing a summary charge of possess cartridge ammunition contrary to s124(1) Firearms Act[2] and you have pleaded guilty to that charge which attracts a maximum penalty of 40 penalty units.
2. The maximum penalty for the charge of burglary is 10 years' imprisonment. The maximum penalty for theft of a firearm is 15 years' imprisonment and the maximum penalty for theft is 10 years' imprisonment.
3. I note that Charges 2 and 3 are rolled-up charges.

1. The circumstances of your offending were set out in a summary of prosecution opening tendered on the plea as Exhibit A.[3]
2. At the time of the offending, you lived at 19 Destination Drive in Greenvale. The neighbouring property at No.20 was occupied by your wife Melis Kankal's family.
3. The offending was carried out in the company of Mr Beyler Kaya who lived at 1/54 Pearl Drive, Craigieburn, with his wife.
4. You and your co-offender were associates and spent time together at the Craigieburn Sporting Club. At the relevant time you were on bail in respect of the same offending, with conditions not to associate with one another.
5. The property where the offending occurred was on Captain Pearson Drive, Mickleham. It is a detached property with a primary residence and several large exterior sheds. The owner of the property, Mr Webb, resided at the address Tuesday to Thursday and elsewhere on other days.
6. In August 2024, Mr Webb was in the process of selling the property. Mr Davinder Singh, of Skad Real Estate agency, was handling the sale on his behalf.
7. On 31 August 2024 at approximately 2:10 pm, you attended the property in a four-wheel drive Mercedes by prior appointment. Upon attendance you introduced yourself as 'John' to Mr Singh and gave your mobile telephone as 0461 474 340 which was registered in your name.
8. During the inspection, you, as 'John', video-called your wife throughout the inspection. The wife explained that as 'John' did not speak English, she would liaise with the agent on your behalf. Mr Singh showed you through the premises and outbuildings. The walk-through lasted some 15 to 20 minutes.
9. Records kept by Telstra, plotting the connection of phones to nearby towers, indicate that your mobile telephone remained in the vicinity of Captain Pearson Drive, Mickleham, for several hours that afternoon.
10. Between the course of the evening of 31 August and the following day, being 1 September 2024, you and Mr Kaya forced entry to the premises at the Mickleham property with an intent to steal. You ransacked the property and stole the following items:

(a) an Australian passport in Mr Webb's name

(b) two Australian Defence Force medals and a Soldier's Medallion for exemplary service awarded to Mr Webb;

(c) multiple hand and power tools; and

(d) $AUD2,000 in cash.

1. The firearms safe was located in an exterior garage proximate to the main property. You and Mr Kaya ripped the safe off its base and stole the following property:

(a) three firearms registered in Mr Webb's name being:

(i) a Boito Reuna break open shotgun firearm with serial number 521258;

(ii) a Bruno model 2 .22 calibre bolt action rifle with serial number 319170; and

(iii) a Gamo .22 air calibre air rifle firearm with serial number 041C22832704.

(b) You also stole a significant quantity of various ammunition;

(c) a firearms cleaning kit; and

(d) a green ammunition box.

1. On 1 September 2024, on two separate occasions in the afternoon, a grey Mercedes with registration plate DEO 515 was observed loitering outside the Mickleham premises. Dash camera footage provided by Ms Michelle Nitchie, captured the car at the front fence of the property at 4:26 pm. Ms Nitchie observed a male seated in the driver's seat of the parked car.
2. On 2 September 2024, Mr Webb discovered the burglary and reported the incident to police. Police attended later that day and photographed the premises. Police swabbed for fingerprints, with no success. A cigarette butt, that Mr Webb confirmed did not belong to him, was seized from the driveway by the letterbox.
3. On 3 September 2024, you were arrested in the company of an associate, Mr Bilal Gurlu, at Red Rooster in Campbellfield. You were driving the grey Mercedes with registration DEO 515 at the time. That vehicle was registered to your wife, Ms Melis Kankal.
4. Examination of your phone revealed communications with Mr Singh, the real estate agent who managed the sale on behalf of Mr Webb.
5. Your call charge records indicate your phone was in close proximity to Captain Pearson Drive, Mickleham, on several occasions during the timing of the burglary on 31 August 2024 and 1 September 2024.
6. Police obtained and examined Mr Gurlu's phone. An image was located that was taken earlier on 3 September 2024 at 2:44 am. The image depicted a Bruno model 2.22 calibre firearm, a firearm cleaning kit and ammunition on a concrete floor which was the same firearm stolen from Mr Webb's property. Your shoe is also visible in the photograph. You were wearing the same shoe at the time of the burglary and at the time of your arrest.
7. Police executed a search warrant at your premises at 19 and 20 Destination Drive, Greenvale. Police located a single .22 calibre round of ammunition which was the same ammunition stolen from Mr Webb's firearms cabinet.
8. Police executed a search warrant at Mr Gurlu's premises at 17 Kensley Court, Craigieburn. Police located a single .308 calibre Winchester rifle round which was the same round stolen from Mr Webb's firearms cabinet. Mr Webb held this ammunition for his son who owned a .308 calibre firearm. It is noted that this is the same type of ammunition depicted in the photograph located on Gurlu's mobile phone.
9. On 4 September 2024, police were able to access and convert CCTV provided by Mr Webb of the burglary at his premises. The CCTV camera situated in the exterior garage containing the firearms safe captured you and your co-offender at various times on 31 August and 1 September.

(a) Both of you are visible in CCTV at approximately 3:53 pm on 31 August.

(b) You were captured again from 1 September. Your face was visible at 7:32 pm, when, upon noticing the camera, you momentarily hid in a nearby room before shining your torch into the lens and knocking down the camera.

1. On 4 September 2024 police attended at your address and re-arrested you and conveyed you to Broadmeadows police station.
2. You denied attending the Mickleham property at any point and you denied stealing the firearms and other items when it was put to you.
3. On 5 September police conducted a search of Mr Kaya's premises in Craigieburn and seized:

(a) keys;

(b) black sketcher shoes; and

(c) a further mobile phone.

1. He was arrested and taken into custody. An examination of his phone and internet history searches revealed the following on 3 September:

(a) 'Gamo GX350 .177 with scope'; and

(b) 'Gamo Coyote Tactical .2 PC'.

1. Gamo is the model of the air rifle stolen from Mr Webb's premises.
2. On 12 September 2024, police obtained transaction statements in respect of Mr Kaya's accounts. A cash withdrawal was identified from an ATM at the National Australia Bank Craigieburn branch on 31 August at 11:15 pm. CCTV obtained from the branch depicts Mr Kaya exiting the front passenger seat of your Mercedes and accessing the ATM. The CCTV depicts that Mr Kaya was wearing the same clothing and shoes as depicted in the CCTV from the Mickleham residence at the time of the burglary.
3. On 20 September Mr Webb's passport was handed into police by a Mr Winston Brunley. Mr Brunley found the passport lying in the grass while out walking on Somerton Road near Greenvale Reservoir Park.
4. The firearms have not been recovered, nor have the power tools, war medals and cash.

1. You were arrested and charged on 4 September 2024 and remanded in custody. You were, on a later date, bailed on conditions that you comply with CISP. You ultimately ran a contested committed and were committed to this court on 4 March 2025.[4] The matter was listed for trial on 11 November but resolved the following day before a jury was empanelled.
2. You have accrued 267 days of pre-sentence detention since your remand in custody.
3. I note that your co-offender, Mr Kaya, is yet to be sentenced for this offending but has pleaded guilty to various charges.

1. The victim of your offending, Mr James Webb, has described how significantly your actions have affected his 'day to day life' in a victim impact statement.[5]
2. He writes of his difficulty sleeping and he and his wife's newfound 'sense of fear and vulnerability', to the extent that his wife refuses to stay in the house. He writes of driving back after leaving the house to double and triple check the doors are locked, such is his fear of a repeat of this invasion of his home where he was entitled to feel safe or at least feel like his possessions were safe.
3. Further, he is devastated by your theft of his Australian Defence medals that he rightfully earned after serving 40 years in the military. No price can be put on the significance of these items. Mr Webb also struggles with significant anxiety, fearing that the weapons you stole could be used for nefarious reasons.

1. You had no prior convictions at the time that the offending took place.
2. I note, however, you were on bail for other burglary offending at the time. You were ultimately sentenced to a 12-month community correction order for this offending on 1 September 2025 in the Magistrates Court.[6]
3. It is submitted on your behalf that this offending took place over a relatively short period of time in 2024 and was a consequence of 'your drug use (leading) to a significant fall from grace' for you.[7]
4. You have been charged with four subsequent charges of burglary spanning a number of months earlier this year, beginning on 12 February 2025, with the last offence taking place on 6 May 2025.[8] You have also been charged with a number of driving and drug possession offences which are said to have taken place on 28 April this year. These are not prior matters and therefore cannot be treated as such.

1. The prosecution submits that this offending falls toward the higher end of seriousness due to the following features, each of which I accept:

(a) The offending involved a number of firearms which potentially causes a danger to the community. The risk is exacerbated in that the firearms that were stolen were sold and therefore likely circulated in the community to people unlicensed to carry firearms and may be used to carry out additional offending.[9]

(b) You were on bail for similar offending at the time that you committed the offences upon which you fall to be sentenced today.

(c) Furthermore, there was a significant degree of planning required in the lead- up to the offending - you had multiple opportunities over several hours to desist and instead followed through with the offending. Mr D'Arcy submits that your moral culpability is high given your attendance at the property with a real estate agent to look at the property and then later returning with your co-offender to commit the offences. I accept that this is so.

1. I turn now to your personal circumstances.[10] You were born in November 1988 in Istanbul, Turkey. You are 35 years of age.
2. You moved to Australia in 2019 and report a positive upbringing with no family violence and no drugs or alcohol in the home. Your father was a police officer in Turkey.
3. You were educated in Turkey. You completed a two-year diploma at the University of Istanbul in electronics. You then went into military service for four and a half years from 2008 to 2012. Military service in Turkey is compulsory for 15 months and you chose to continue for longer than that as a Senior Corporal.
4. Between 2013 and 2016 you worked in retail at Calvin Klein as a sales manager. Between 2016 and 2019 you set up your own business, operating a shop that sold hunting equipment. You led a pro-social life in Turkey with consistent employment.
5. You were married to your first wife in Turkey between 2013 and 2018. Together you have a nine-year-old daughter. You speak to your daughter on the phone as she and your first wife remain in Turkey.
6. You married your second wife, Beyza Ozdemir, in 2018. You moved to Australia in October 2019 with her. You wanted to move to Australia for a better life. You also have a daughter with her who is four and a half years old, who lives in Australia and who you see frequently.
7. You and Ms Ozdemir separated in 2021. You met your partner, Melis Kankal, six months after you separated from Ms Ozdemir. Ms Kankal is of Turkish descent, however, is a citizen of Australia who was born and raised in Australia. She is currently pregnant and due to give birth in February 2026.
8. You moved to Australia initially on a tourist visa. You have been a permanent resident since the start of 2020. You are particularly concerned that you may be deported to Turkey. This would not only result in you being required to move away from your family and the life that you have established in Australia, but you are also particularly concerned about the political situation in Turkey and your associations with the 'Gulen Movement' by virtue of where you attended your schooling. You remain fearful as to any consequences of this association.[11]
9. You were initially employed in Australia as a bricklayer for your former father-in-law. Between 2021 and 2022 you worked as a carpenter for ARCON Group. In 2023 you worked at the STAR carwash group for six to seven months.
10. Your mother and father separated in early 2023. This resulted in your mother and sister moving to Australia to live with you the same year.

1. There have not been any psychological reports tendered on the plea and it is not submitted that you are suffering from any mental health issues.
2. Mr Redwood submits that you were a pro-social member of society for the first 35 years of your life, and you have historically never had any issues with alcohol or substance use. However, your offending was reportedly precipitated by a significant drug addiction that began in 2021.[12]
3. This began following a separation with your second wife which resulted in you being kicked out of the family home and becoming homeless for a period. You were sleeping rough in construction sites and felt depressed, feeling you did not have a support system in Australia, particularly as you do not speak the language properly.
4. You began living with a stranger in a share house who introduced you to drugs, including cocaine and methamphetamine. By the end of 2023 you had developed a methamphetamine addiction and had begun gambling excessively and drinking alcohol.
5. You met your co-offender, Mr Kaya, when he worked on your car as a mechanic. You began using methamphetamine together.
6. You were previously on CISP bail for this matter between the period of 29 November and 7 May 2025. The final CISP progress report demonstrates that you engaged well in the program and attended eight to ten appointments with a psychologist over this period.[13] However, your bail was revoked following further offending which you were alleged to have committed during that bail period.
7. You have undertaken a number of courses in relation to your drug and alcohol use over the period that you have been in custody.[14]
8. Your most recent drug test in custody on 2 November was negative to all substances.[15]

1. Your counsel has tendered a number of character references from your friends and family.[16]
2. Your wife writes of your reliability and your pride in 'being a good husband and dependable person.' She calls you the 'glue that holds your family together.' She writes of a previous miscarriage she suffered in 2023 and how difficult it has been for her to experience this pregnancy without you whilst you have been remanded. She believes that you 'fully understand the consequences of (your) mistakes' and that you now want to 'do what is right for (your) family.'
3. Mr Jesse Theoclitou is a family friend of yours and describes you as a 'hardworking individual' with a 'strong character.' He says 'the current situation does not reflect the person (you) truly are. Another friend, Mr Joseph Altay, writes of your 'calm nature and warm character.'
4. Two letters have also been tendered from former detailing clients of yours who write of your work ethic and attention to detail. Mr Redwood submits that all who wrote references are aware that you are facing sentence for these charges, despite the fact that some appear to read as though they are work related references.
5. It is clear that you are well respected within your community. You are fortunate to have extensive family supports and this has been evident throughout your court proceedings. This bodes well for the supports available to you upon release from custody.

1. You are the holder of a permanent resident visa. There is the potential that should you be sentenced to a term of imprisonment exceeding 12 months that you may be deported. I cannot speculate about this, however, I accept that the prospects of potential deportation, particularly in circumstances where you have a well-established life in Australia with a young family and thus face the opportunity of missing settling in Australia, would weigh heavily upon you and make a term of imprisonment difficult. I also accept that you have concerns about consequences in your home country should you be required to return and the stress this may cause you in custody. [17]

1. Furthermore, your counsel submits that your inability to physically, emotionally and financially support your pregnant wife who has suffered a number of miscarriages previously will cause you considerable stress and make prison more burdensome for you. You are also unable to support your daughter and extended family. I accept this and take it into account in accordance with the principles set out in Markovic v The Queen, noting that your wife is due to give birth in the coming months.[18]

1. I take into account your plea of guilty. This was not a plea of guilty entered at an early stage, it was very late falling on day two of the listed trial.
2. As I have said, the matter proceeded with a contested informant-only committal and it was only upon the second day of pretrial argument that you entered a plea of guilty. However, no jury had been empanelled and no witnesses had been called to give evidence at trial.
3. Your counsel submits that your plea nevertheless had 'obvious and genuine utility' and is an indicator of remorse.
4. I accept that your plea of guilty demonstrates a willingness to facilitate the course of justice and is of considerable utilitarian value. You have spared the community and witnesses the time and expense of having to give evidence at trial.

1. Mr Redwood submits that you have strong prospects of rehabilitation.[19] This is due to your history of pro-social behaviour and your strong work history. Furthermore, you have strong family supports outside of custody and you are motivated to improve yourself for them, particularly as your wife enters her last few months of pregnancy.
2. You have reportedly found your period in custody 'sobering' and you are significantly motivated to avoid repeating the experience.[20]
3. As I have said, to your credit you have completed a number of courses while in custody and have obtained a number of certificates which were tendered by your counsel, relating to employment, wellbeing and substance use. You also engage in maintenance work in the prison five days a week.[21] This is commendable particularly given your challenges with the English language. You have remained substance free whilst in custody.
4. The prosecution submits that you have guarded prospects of rehabilitation.[22] The court has been provided with a number of police summaries regarding further alleged offending taking place between February and May of this year whilst you were on bail. You also have a matter pending before the Broadmeadows Magistrates Court which is listed next on 20 January 2026.
5. You were sentenced for similar offending which you committed following the commission of these offences upon which you fall to be sentenced today, being two charges of burglary, two charges of stolen goods and two charges of dealing with property suspected of being proceeds of crime, having been sentenced on 5 September this year. Upon your release from custody in relation to this offending you will be required to carry out a community corrections order with respect to that other offending, which includes 150 hours of community work and rehabilitation and treatment components.
6. A letter of apology written by you to the court was tendered.[23] In that letter you write that getting involved in drugs and committing this offending 'has been the greatest mistake of (your) life.' You write of the 'difficult days' you have spent in prison, particularly given that you do not speak English, and of your shame that your pregnant wife, two daughters, mother and sister are suffering 'as a result of (your) mistakes.'
7. You state in your letter that in custody you have learnt a 'painful but important lesson' as to the consequences of your errors and that you 'will never again use drugs or associate with anyone who does.' Time will tell as to whether you follow through with this promise. It is clear, particularly in light of the subsequent offending, that you will need to do much hard work to free yourself from your drug addiction and anti-social associates in order to contribute positively to your community and to avoid coming before the court again.
8. I note you have also prepared a letter to your victim.[24] It is a matter for the victim as to whether he wishes to read that.
9. Corrections have assessed you as a medium risk of re-offending. I accept that you are remorseful for your offending, as expressed in your letters to the court and to Corrections. However, this has to be tempered with your late plea of guilty. Whilst I accept you come before the court with no prior criminal history (a significant factor in mitigation) you do have a number of outstanding and serious charges which, whilst they may reflect a period in which you have struggled, do not necessarily bode well for your rehabilitation prospects. Overall, however, I find that you have good prospects of rehabilitation and these are enhanced if you engage in appropriate supports.

1. You were initially remanded for this offending on 5 September and later bailed on 29 November 2024. However, your bail was revoked on 28 May this year as a result of further offending. You have remained in custody since then. Again, you have described your time in custody as difficult. You say you are suffering emotionally and financially. I accept that this is so, but again, this is a product of your own making, unlike Mr Webb who has suffered the effects as a result of your conduct. As I have noted, you have used your time in custody productively and you have, as you describe, learnt a painful but important lesson. Hopefully, this will be the catalyst for you to improve yourself in the future.
2. Prior to bail being revoked you were remanded on other offending for a period of 20 days, offending involving burglary charges and which ultimately resulted in a community corrections order. That period spent prior to bail being revoked to this offending is accordingly not taken into account as pre-sentence detention with respect to the other offending. I take this period of 20 days in custody into account pursuant to the principles set out in R v Renzella. [25]

1. There are a number of basic purposes for which a court may impose sentence, namely, just punishment, both specific and general deterrence, rehabilitation, denunciation and protection of the community. In determining an appropriate sentence, I am required to take into account these objectives as well as various other matters including the gravity of the offending, your culpability, the impact on the victim and your personal circumstances.
2. The sentence I pass must balance the interests of the community in denouncing criminal conduct with the community's interests in ensuring that as far as possible you are rehabilitated. I am to have regard to the principles of parsimony, and I do so.

1. General deterrence is an important consideration in sentencing you for these offences. Other members of the community must understand that such serious criminal offending will attract significant punishment. Burglary, and in particular the theft of firearms, is a serious offence. Given that those firearms have not been recovered, the community needs to understand that this sort of offending will attract jail. Moreover, in this case I am of the view that specific deterrence and community protection are also to be given some weight in light of your subsequent offending.
2. Just punishment and denunciation must also be given primary consideration in my instinctive synthesis.

1. Your counsel has provided me with a number of comparable cases for similar offending. Of course, no two cases are alike. I have had regard to each of the cases provided and more broadly to current sentencing practices for this type of offending. The sorts of sentences imposed by this court have ranged from head sentences with a non-parole period to combination sentences, or even in some instances to a community corrections order. Two of the cases raised on the plea, the matters of Kowalski[26] and Webster[27], involve similar offending but in each case the offender had also spent a significant time in residential rehabilitation. Each of those offenders came before the court with relevant prior criminal histories. Another case of Causby was also relied upon which resulted in a combination sentence, albeit that there were different charges upon which that offender was sentenced.[28] I have had regard to each of these cases as part of the instinctive synthesis

1. Your counsel submits that having regard to the period spent in custody on remand I should consider a combination sentence that does not involve any further immediate imprisonment.[29] I have had you assessed for a community corrections order with respect to a combination sentence, and you are deemed suitable, however, are considered a medium risk of re-offending.
2. The prosecution submits that having regard to the gravity of the offending, I should impose a term of imprisonment with a head sentence and non-parole period.[30]
3. Ultimately, I am prepared to place you on a community correction order, but in combination with imprisonment. The effect will be that you will need to serve a further period of imprisonment. I consider this as necessary to reflect the seriousness of the offending, your culpability for the offending, whilst having regard to the basic sentencing principles. As I have said, I have taken into account your personal circumstances. The reality is that you are at a crossroads in your life. You can continue down the path of drug use and eventually find yourself before the courts again and again, routinely jailed, or you can make the most of the opportunity to rehabilitate yourself.
4. I have determined that an aggregate sentence is appropriate with respect to Charges 1, 2 and 3 having regard to the fact that the offending is founded on the same facts or form. I am intending to impose a separate penalty with respect to the summary charge.
5. Could you stand up please Mr Sahin.

1. On Charges 1, 2 and 3, you are convicted and sentenced to 10 months' imprisonment, to be followed by a community correction order.
2. On the summary charge you are convicted and fined the sum of $500.
3. You have already spent 267 days in custody which I declare as presentence detention. This means there is a further period to be served and then you will be, upon release, placed on a community corrections order.
4. That order will commence upon your release. The duration of the order will be for two years.
5. There are a number of conditions attached to the order:
   • You are to be under the supervision of Corrections for a period of two years;
   • You must undergo treatment and rehabilitation for drug and alcohol use;
   • You must perform 200 hours of unpaid community work;
   • I will allow 100 hours of rehabilitation to count toward the unpaid community work component.
6. I am going to order that you attend for judicial monitoring, as recommended, in six months, that is, to come back before the court on 25 May at 9:30 for judicial monitoring.
7. There are also a number of core conditions that attach to a community corrections order.

• You must not commit any other offence that is punishable by imprisonment during the two-year period.
• You must comply with any and all obligations and requirements as prescribed.
• You must report to and receive visits from Corrections during the period of the order.
• You must report to the nearest Community Correction Centre, which I believe is in Coolaroo, within two clear working days from release from custody.
• You must let a Community Correction officer know within two working days of a change of address or employment.
• You must not leave Victoria without first getting permission.
• You must obey all lawful instructions and directions from Corrections.

1. You will need to comply with the conditions of the community correction order. If you do not comply with the conditions of the order, for instance, if you were to commit further offences during the two-year period, or if you do not undertake the rehabilitation component or unpaid community work, you will likely find yourself back before the court on a breach. If that were to occur, I would need to resentence you for this offending and it is likely there would also be a penalty for the breach itself.
2. If I am required to resentence you for this offending it is very unlikely you will be given a further opportunity to undertake community Correction work.
3. HER HONOUR: Shortly you are going to be asked to sign a document indicating that you understand the conditions of the community correction order and that you agree to abide by them. But while that is occurring, I am just going to ask you orally, do you understand the conditions as I have read out to you.
4. ACCUSED: Yes.
5. HER HONOUR: Do you need me to repeat anything.
6. ACCUSED: No.
7. HER HONOUR: And do you agree to abide by those conditions.
8. ACCUSED: Yes, I do.

1. I declare 267 days presentence detention as time already served to be deducted from the period of imprisonment imposed.

1. Pursuant to s6AAA of the Sentencing Act,[31] I indicate that but for your plea of guilty, that is if you had pleaded not guilty and been found guilty at trial, I would have imposed a total effective sentence of two years and two months' imprisonment with a non-parole period of 15 months' imprisonment.

1. Are there any orders that are sought in this case, Mr D'Arcy?
2. MR D'ARCY: Disposal order.
3. HER HONOUR: There was an order for disposal, yes. I make the order for disposal in the terms sought, which from recollection was by consent.
4. HER HONOUR: All right, Mr Sahin, you are now going to be asked to sign the document indicating you understand the community correction order and agree to abide by that. Mr Redwood, you're welcome to approach if you wish and hopefully with the assistance of the interpreter, he'll be in a position to sign that now.
5. Yes, all right now, that document has been signed. I thank counsel for your assistance in this matter. Adjourn the court please, and if you could take Mr Sahin back into custody, thanks.

[3] Summary of Prosecution Opening dated 13 November 2025 ('Exhibit A').

[4] Outline of Prosecution Submissions on Plea dated 13 November 2025 and Further Submissions on Plea dated 24 November 2025('Exhibit C').

[5] Victim Impact Statement of Mr James Webb dated 29 March 2025 ('Exhibit B').

[6] Exhibit C, Further Submissions [1].

[7] Outline of Defence Submissions on Plea dated 13 November 2025 and Further Defence Submissions dated 21 November 2025 ('Exhibit 1').

[8] Exhibit C, Further Submissions [1].

[13] Final CISP Progress Report for Can SAHIN dated 6 May 2025 ('Exhibit 2').

[14] Bundle of Course Certificates dated between August 2025-November 2025 ('Exhibit 3').

[15] Drug Test dated 2 November 2025 ('Exhibit 7').

[16] Bundle of Character References dated between 12 October 2025 -13 November 2025 ('Exhibit 4').

[17] Guden v The Queen [201] VSCA 196.

[18] [2010] VSCA 105; (2010) 30 VR 589.

[23] Interpreted Letter of Apology written to the court by the Accused dated 25.11.25 ('Exhibit 6').

[24] Interpreted Letter written by the Accused to the Victim dated 25 November 2025 ('Exhibit 5').

[25] [1997] 2 VR 88.

[26] DPP v Kowalski [2023] VCC 385.

[27] DPP v Webster (A pseudonym) [2021] VCC 1509.

[28] DPP v Causby [2020] VCC 1905.