© 2026 Zoe. All rights reserved.
Zoe is a legal information platform. Always consult the Federal Register of Legislation for authoritative text.
[2002] VSCA 70
Court of Appeal (Vic)
2002-05-22
PHILLIPS, C.J., CHARLES and CHERNOV, JJ.A.
Original judgment source is linked above.
The date from which a new non-parole period fixed under s.14(1) of the Sentencing Act 1991 has effect
"(1) If - (a) a court has sentenced an offender to be imprisoned in respect of an offence and has fixed a non-parole period in respect of the sentence; and (b) before the end of that non-parole period the offender is sentenced by a court to a further term of imprisonment in respect of which it proposes to fix a non-parole period - the court must fix a new single non-parole period in respect of all the sentences the offender is to serve or complete. (2) The new single non-parole period fixed at the time of the imposition of the further sentence - (a) supersedes any previous non-parole period that the offender is to serve or complete; and (b) must not be such as to render the offender eligible to be released on parole earlier than would have been the case if the further sentence had not been imposed."
"Sentencers do, then, have a choice as regards the date from which they make a new single non-parole period run, a choice the exercise of which must result in the fixing of a different period according as one commencing date or the other is selected. Because the sentencer has a choice, it is essential that there be no doubt about which date has been adopted. Sentencing judges do, it seems, normally specify the date in fixing the period. If they do not do so, it is highly likely that the period fixed upon will show, in the light of the surrounding circumstances, which date was intended. But this will not necessarily be so, and in any event it is undesirable that a question of this kind should depend upon inference. I therefore think it desirable that there should be uniformity of practice and that what now appears to be general should become universal in the sense that all new single non-parole periods should be made to commence on the date on which they are fixed."
"Regard must be had in re-sentencing to the period during which the applicant's detention in custody was doubly warranted. This can be done by this Court's adopting the declaration concerning 93 days' pre-sentence detention already made and by this Court's reducing by six months, to allow in a broad way for the period from September to March, the head term and the non-parole period which it would otherwise determine upon."
"It applies only where an offender is sentenced to a term of imprisonment and there is a period of time during which the offender was held in custody in relation to proceedings for that offence or proceedings arising from them and for no other reason. In other cases the section is silent and a court is not only empowered but obliged as a matter of justice to take pre-sentence detention into account. It is true that the legislative history reveals an intention that that should be done by declaration rather than by adjusting the sentence, and it might well be thought desirable to amend s.18 so that that may be done in all or a greater number of cases."
"It follows that the law expounded by Brooking, J.A. in Heaney's case is, unsurprisingly, correct in principle and consistent with s.18. Where that section applies, pre-sentence detention is to be reckoned as a period of imprisonment already served under the sentence, and a declaration made to that effect, unless the sentencing court or the court fixing a non-parole period in respect of the sentence otherwise ordered. Pre-sentence detention to which s.18 does not apply is to be taken into account in the exercise of the Court's discretion. It should ordinarily be taken into account at the first opportunity, as it was in Heaney's case, and not left to the court imposing a later sentence."
"to a period of custody declared on a previous occasion under this section or s.35 as reckoned to be a period of imprisonment or detention already served under another sentence of imprisonment or detention imposed on the offender."
"It is no longer necessary for the time held in custody to be exclusively referable to the offence for which the offender is being sentenced before a declaration pursuant to section 18(1) of the Act is made"
and gave the decision in Renzella as an example. The obvious intention behind the introduction of s.18(2)(d) was that since the ability to declare a period of custody had been widened by the amendment to s.18(1) it became necessary to ensure that prisoners were not on a second occasion given the benefit in sentencing of a period of custody which had already been taken into account.
The consequences of the fixing of a new single non-parole period under s.14 of the Sentencing Act
Conclusions as to the sentence imposed on 30 January 1998
Conclusions as to the sentence imposed on 23 March 1998
"The aggressive use of knives is becoming all too common. There is a real need to deter their use. The maximum sentence provided by Parliament for recklessly causing serious injury is ten years' imprisonment. I regard an appropriate sentence in your case as being three years. You were, on 30 January of 1998, sentenced to five years' imprisonment with a minimum of three-and-a-half years, in relation to other matters. I order that eighteen months of the sentence imposed by me become concurrent with that term, leaving you with a head term of six-and-a-half years. I fix a new non-parole period of four years and eight months. I declare that you have been imprisoned in relation to other matters that have not proceeded to trial for a period of 167 days. That term is to be credited towards your present sentence; so that you are deemed to have already served 162 days of it."
1. The sentence imposed on 30 January 1998 properly included a s.18 declaration in respect of the period of 161 days pre-sentence detention. To be consistent with Renzella, the sentence should also have taken into account the earlier period of 167 days served in custody in 1995, not by a declaration, but by an appropriate reduction in sentence which would, all other matters being equal, have involved a reduction in the head sentence and non-parole period fixed of, say, six months.
2. (a) Since this course was not followed on 30 January, the sentence imposed on 23 March 1998, on the assumption that the judge remained of the view that the period of custody was not related to proceedings for the offence for which the applicant was then to be sentenced, should also have taken into account the earlier period of 167 days custody in like fashion to that set out in (1) above.
(b) In fixing a new single non-parole period, the judge on 23 March 1998 should have specified when the new period was to commence. If it was his Honour's intention that it commence on 23 March, rather than 30 January, then his Honour should have taken into account in sentencing that a further period of nearly two months had already been served, by an appropriate reduction in the non-parole period.
3. For the purposes of this appeal I assume that had all these matters been taken into account, Judge Holt would have sentenced the applicant to a head sentence of 4½ years and a non-parole period of three years, in addition making a declaration under s.18(1) for the period of 161 days. When Judge Neesham came to sentence the applicant, no declaration of pre-sentence detention would have been necessary. On the assumption that 18 months of the new sentence were to be concurrent with the old, the new head sentence would have become six years. If his Honour intended that 14 months be added to the non-parole period (now assumed to be three years) the new single non-parole period would become four years, if expressed to date from 23 March 1998. The applicant would retain his entitlement to the 161 days declared by Judge Holt, which would have resulted in his earliest release date being placed in October 2001.
and that the applicant remains entitled to the period of 161 days pre-sentence detention in respect of which Judge Holt made the declaration on 30 January 1998.
[1] (1997) 93 A.Crim.R. 56, at 59.
[2] (1996) 88 A.Crim.R. 65 at 75.
[3] See, e.g., the memorandum from the Office of the Correctional Services Commissioner dated 20 November 1998, Exhibit SL2 to the affidavit of Spencer James Lambert sworn 6 May 2002.
[4] [2002] VSCA 17. Winneke, P. and I concurred.
[7] Unreported, Court of Appeal, 27 March 1996 at p.6.
[9] Winneke, A.C.J., Charles and Callaway, JJ.A.
[14] Cf. Krasnov & Shlakht (1995) 82 A.Crim.R. 92 at 99.
R
Stares [2002] VSCA 70
CRIMINAL LAW - Sentencing - Applicant first sentenced on 30 January 1998 - Sentenced again on 23 March 1998 - New single non-parole period fixed - Practice in fixing new single non-parole period - Date of commencement - Presentence detention - Effect of fixing new non-parole period upon periods of presentence detention previously declared - R. v. Rich [2002] VSCA 17 - Sentencing Act 1991 ss.14, 18.