Sentencing principles for s 95(1) Crimes Act offences
- The court in Azzi v R [2008] NSWCCA 169 at [37] accepted that the guideline judgement of R v Henry (1999) 46 NSWLR 346 ("Henry") is a "relevant reference point" in sentencing offences contrary to s 95 of the Crimes Act. However, because Henry considers a circumstance where a weapon is used, the use of the armed robbery guideline must be approached with caution: R v Tortell [2007] NSWCCA 313 at [14]. Henry, also involved a late plea of guilty. The sentencing judge must not adopt a term of imprisonment of 4 - 5 years as a prima facie starting point, even when all of the characteristics set out (at 162) of the guideline judgement are satisfied (apart from the characteristic that the offender was armed).
- Where the s 95 robbery offence is based on conduct consisting of the threat of violence, it is impermissible to apply s 21A(2)(b) of the Crimes (Sentencing Procedure) Act 1999 ("C(SP)A") and take into account any actual violence without double counting: Manze v R [2006] NSWCCA 36 at [26].
- In assessing the objective seriousness of the offending in respect of each offence of aggravated robbery pursuant to s 95 (1) of the Crimes Act, the whole of the circumstances have to be taken into account, including the nature and extent of the corporal violence which was the aggravating factor in each case: R v Forsythe [2020] NSWDC 99 (9 April 2020) at [68].