This table is intended to be used as a guide only. Individual cases should be read if they are to be relied upon.

 

Murder - Accessory After the Fact

s.349 Crimes Act - Maximum penalty:  25 years
 

Name​Offence​Plea​Sentence​AppealRecordInvolvement & Summary

N Farroukh

(40)

 

M Farrounkh

(52)

 

NSW CCA

29.3.1996

Accessory after fact murder

VG

MT 6m

AT 12m

Crown AA

MT 18m

AT 6m

nil

Husband and wife of Lebanese background - Close relative stabbed 19y daughter following her refusal to take part in arranged marriage - Assisted principal offender in removing incriminating evidence - Told their children to keep silent about the killing – Lied to police – Principal offender escaped to Lebanon and not brought to justice.

Prior good character – 6 children

Discussion as to sentences for accessory after fact to murder

Do

(20)

NSW CCA

7.5.1997

Accessory after fact murder

Receiving

PG

12m PD

Crown AD

Nil

Good friend involved in shooting of shop owner during armed robbery – Agreed to provide simple alibi – Held $1500 stolen money on behalf of friend for future legal costs (receiving charge) - Alibi not provided as friend confessed to police - Never intended to provide alibi.

Szkudelski

(40)

NSWSC [178]

12.3.1999

Barr J

Acc after fact to murder

PG

3y GBB

 

Record related to alcohol abuse

Victim bashed and strangled by Helmout brothers – offender assisted in disposing of body –acted out of fear – reported offence to police and provided assistance – danger of custodial sentence

R.A.F.

(14)

NSWSC [615]

Sully J

23.6.1999

Acc after fact to murder

PG

4y GBB

 

 

Female in relationship with primary offender (Bowhay) – both out of control – Victim bashed and stabbed in fight - left scene and travelled instate with primary offender

Evidence of rehabilitation – mother to young son

Waters

(20)

NSWSC [893]

Simpson J

27.8.1999

2 x Acc after fact to murder

PG

18m PD

(3m 6d PSC)

 

Minor

Present at time of killing of two females by Rose – assaulted second victim – provided minor assistance in leaving scene – failed to report offence over 2.5 years

Assistance - contrition

Leung

(19)

NSWSC [824]

Barr J

9.8.2000

Acc after fact to murder

PG

2y GBB

 

 

Attended service station with primary offender – after swearing at attendant walked outside – primary offender unexpectedly shot attendant– suffering mental illness – provided accommodation for 48 hours – acted out of fear

Student from Hong Kong – no family support at time of offence – immaturity – voluntarily surrendered – remorse - rehabilitation

Faulkner

NSWSC [944]

5.10.2000

Wood CJ at CL

2 x Acc after fact to murder

 

Sched:

4 drug and dishonesty off

PG

4y 4m

NPP 2y 8m

 

Nil

Victims killed by Naismith in retaliation for drug rip-off – stood guard over first body as instructed – assisted over several days in disposing of cars, bodies and weapons – element of fear – upper range of seriousness

Involved in drug dealing with primary offender

Phan

(18)

NSWSC [1069]

G. James J

22.11.2001

 

126 A Crim R 257

Acc after fact to murder

PG

2y, suspended

 

 

Deceased shot in car three times – present in car – lied to police and doctor in attempt to cover up

Undertaking to give evidence against co-offender – Vietnamese – PSC: 1 year 10 months

Quach

(22)

NSWSC [1205]

17.12.2002

Simpson J

Acc after fact to murder

PG

2y, suspended after 3m for 1y 9m

(10m PSC)

 

Nil

Female victim killed while sleeping with primary offender – offender assisted in disposing of body – disposal of body in upper range

Vietnamese - remorse

Dileski

(26)

(2002) 132 A Crim R 408

Accessory after fact murder

 

PG

5y

NPP 3y

AA

2y

NPP 1y

drugs, dishonesty. On bond.

Assisted friend who had murdered employer at factory - Cashed $850 cheque at bank drawn on victim’s account – Waited at factory while friend cashed further cheque – Told friend of victim that victim had already left factory.

Error in taking into account cashing of cheque as particular of offence.

Subsequent assistance to authorities - special circumstances in drug addiction

Galea

(42)

NSW SC [465]

Sully J

30.5.2003

Accessory after fact murder

VG

(third trial)

5y

NPP 2y 6m

(+ 2y PSC)

 

 

Assisted former de facto wife to dismember and dispose of male victim wife had shot dead

Prior good character

Gersteling

(15)

NSWSC [502]

Adams J

8.4.2004

Accessory after fact murder

PG

3y GBB

 

Nil

Saw 17y best friend shoot male stranger in street – picked up and hid gun in grass to protect shooter and ensure no further use – assisted police in locating weapon – spontaneous and emotional reaction

Strong evidence of remorse and contrition – aberration – good prospects of rehabilitation

Ward

(37)

NSWSC [420]

Hulme J

13.5.2004

Acc after fact to murder

PG

3y 6m

NPP 2y 6m

 

Nil

Female assisted male friend who had bashed and slit throat of female partner – Cleaned up blood – Told lies about whereabouts of victim - Stored implicating evidence at house – Hid male from police – Acted in fear

History of abusive relationships – Assistance – Hardship of Special Purpose Prison

Mirad

(28)

NSWSC [701]

6.8.2004

 

Co-offender:

YOUMARAN

(murder)

[2008] NSWSC 762

Acc after fact to murder

PG

2y 6m

NPP 1y 6m

 

Two previous offences of violence 8 and 9 years ago

Offender and 4 others went to hotel where deceased was at a birthday party – bad blood arising from previous altercation between the two groups – offender waited in car while others opened fire, then drove them away. Went to police station to turn self in. Substantial utilitarian discount for PG.

Almirol [No.2]

(38)

NSWSC [323]

Kirby J

13.4.2007

Acc after fact to murder

PG

4y 3m

NPP 3y 2m

 

Nil

Present when victim killed in house by close friend (Troico)– Assisted in cutting up body and removing to remote area – also assisted in cleaning up house – small man – intoxicated at time of offence – shocked and fearful for safety – felt obligation to close friend

Acquitted at trial of murder – from Philippines – remorse – good character

Scowen

(20)

NSWSC [792]

Grove J

20.7.2007

Acc after fact to murder

PG

15m 28d

NPP 11m 28d

 

Record

Female accompanied partner from crime scene into Queensland after fatal stabbing – offender and partner surrendered voluntarily to police two days later – assisted partner in delaying arrest – lower end of range of seriousness

AB

(21)

NSWSC [1517]

Berman AJ

12.12.2007

 

Co-offender:

DAVID

SHAMOUIL

Acc after fact to murder

PG

2y 6m

NPP

1y 7m 18d

 

Driving offences

Drove S and D from scene after witnessing fatal shooting – element of duress – aware S holding gun - short journey – lower range of objective gravity

D sentenced for accessary after the fact

S sentenced for murder

Prior good character – assistance and protective custody – remorse - good prospects of rehabilitation.

Cowen

(32)

NSWSC [104]

Buddin J

22.2.2008

Acc after fact to murder

Conceal serious offence

PG

9mPD

18m GBB

 

Minor

Female failed to advise police of involvement of de facto in forcible detainment of two adults – failed to disclose possession of handbag belonging to female victim – bottom range of gravity - Acted out of loyalty to partner and emotional dependence

Unstable and sexually abusive childhood – alcohol dependency – good character – remorse – good prospects of rehabilitation

Wells

(29)

NSWSC [206]

Grove J

12.3.2008

Acc after fact to murder

PG

3y

NPP 18m

 

Nil

Female assisted male partner (Shepherd) conceal offence over two weeks – observed Shepherd choking female victim – immediately laid trail for false story – delayed calling ambulance – false statements to police –disposed of incriminating evidence – voluntarily assisted until seriously assaulted by Shepherd

Mother to young son – good prospects of rehabilitation

David

(21)

NSWSC [24]

Hidden J

6.2.2009

 

Co-offender:

AB

SHAMOUIL

Acc after the fact to murder

Common assault

PG

2y 6m

NPP 15m

(6m concurrent)

 

Drug offence committed after this offence

Arranged to meet victim at service station to discuss argument between V and S’s cousin – V fatally shot by S during argument – Driven from scene by AB – disposed of mobile phone and shooter’s clothes – arranged meeting knowing V to be forced to apologise by threats or intimidation – no violence anticipated

Assyrian - remorse

Papallo

(25)

NSWSC [1109]

Buddin J

16.10.2009

Acc after fact to murder

 

Sched:

Affray

PG

2y

NPP 17m 2w 5d (immediate release)

 

Short record for minor violence

Involved in scuffle in bar with victim and others - Victim unexpectedly shot dead by friend of offender with handgun – pulled female off shooter protecting female and allowing shooter to escape – returned to bar to retrieve shooter’s bag – spontaneous offence motivated by friendship – at lower end of range

Pre sentence custody – remorse – prospects of rehabilitation

HDR

(19)

NSWSC [1323]

RA Hulme J

4.12.2009

Acc after fact to murder

 

Agg BES

2 x Obtain money by deception

 

Sched:

Take and drive conveyance

Firearm offences

PG

Accessory

3y 9m NPP 2y

 

Total

4y 9m NPP 3y

 

Minor driving offence

With brother broke into property and stole firearms to intimate person who owed money to offender – Later in evening fell asleep then awoke to find father shot dead by younger brother – failed to notify police – used victim’s card to withdraw money – took victim’s car with brother – assisted brother over 14 hours before brother voluntarily attended police station – motivated by loyalty – slightly below mid-range

Prior good character – good prospects of rehabilitation

Urriola

(25)

NSWSC [367]

Fullerton J

30.4.2010

 

NSWCCA [95]

17.5.2012

 

Co-offender:

POSTLEWAIGHT

 

 

[2012] NSWSC 1634

Fullerton J

(re-sentencing)

Acc after fact to murder

Supply comm. qty cocaine

 

Sched:

16 offences

PG

Accessory

6y NPP 4y 6m

Supply

2y 6m

 

Total

6y NPP 5y 6m

 

 

 

New Sentence upon re-sentencing:

 

Total:

6y

NPP 4y 6m

 

AA in part.

Sentencing judge failed to impose NPP in relation to the drug supply offence in accordance with Crimes (Sentencing Procedure) Act s.45(1). Matter remitted to trial judge for re-sentencing.

nil

Assisted male to dispose of body at sea and burn car aware male had fatally shot victim day before – involved in drug dealing with same male over several weeks after murder – `victim killed over drug debt - approved of killing – serious offending

Assistance to authorities (45% discount) – under influence of principal offender due to drug use

Ferrett (No.4)

(47)

NSWSC [956]

Rothman J

27.8.2010

Acc after fact to murder

PG

7y NPP 4y

 

Breached conditional liberty – record for armed robberies, drug offences and assaults

Victim killed by person unknown – involved with victim and others in drug manufacturing – Victim shot dead after talking to police and body never found – helped dispose of body knowing victim murdered to prevent detection of manufacturing – approaching worst case

Long-term drug addiction – suffering emphysema – voluntarily enrolled in rehabilitation program

Postlewaight

(31 at time of second offence)

NSWSC [1272]

Fullerton J

5.11.2010

 

 

Co-offender:

URRIOLA

Acc after fact to murder

s.112(2)

PG

Accessory

8y 6m NPP 6y 6m

 

BES

18m

 

Total:

9y 6m

NPP 7y 6m

 

No relevant record at time of first offence - Acc offence breached parole for supply drug offence

In 2002 assisted in joint criminal enterprise to break into industrial distribution premises and steal gas for purpose of making drugs – driver for group paid to obtain gas on behalf on others – limited role – no involvement in planning or ongoing use of gas – low range

2008 – male shot dead by associate of offender – contract in relation to drug debt – assisted next day in disposing of body at sea – willingly provided vessel and assistance – serious offending – killer was co-offender in earlier offence

Jin

(24)

NSW SC [169]

McCallum J

16.3.2011

4 x Acc after fact to murder

VG

27m NPP 15m

 

nil

Provided two men (2 murders each) with safe accommodation for 2 weeks after murder – unplanned offence – somewhat influenced by one of the men

Prior good character – good prospects of rehabilitation

Fennell

NSWSC [489]

Rothman J

26.5.2011

Acc after the fact to murder

 

Sched:

Accessory after the fact to murder

PG

2y NPP 12m

 

nil

Female – assisted de facto husband after male shot dead during robbery – assisted in disposing of gun and moving body – aware money stolen used to pay bills and buy Christmas presents – harboured offender for five months - valuable assistance - volatile and fearful relationship with de facto

Long history of drug and alcohol abuse – mother of young two children – genuine remorse – good prospects of rehabilitation

Anderson

(21)

NSWSC [1689]

Adams J

5.10.2011

Acc after the fact to murder

 

BES

 

Sched:

5 BES offences?

PG

(20%)

2y GBB

 

Minor

Female - Became aware of killing by boyfriend day after offence – female victim injured during break in by boyfriend and left to die –accompanied boyfriend for five weeks providing assistance – 7m pregnant – did not destroy or hide evidence –committed number of BES offences with boyfriend

Chaotic and difficult childhood – son born in prison on remand – difficulties of seeing son while in remand for murder for 9 months – remorse – relationship with offender marked by domestic violence - assistance

Bullar

(23)

NSWSC [93]

Harrison J

21.2.2012

Acc after the fact to murder

 

PG

FT 2y 25d

(To date from from date taken into custody/ remand. To be released immediately).

 

nil

Female – V and A worked as agricultural workers in Griffith area – V killed by HS known for violent intimidating behaviour toward workers – A was driving HS, GS and V – stopped car to allow them to get out of car – A only aware HS had killed V when HS and GS returned covered in blood without V – A drove HS and GS away- A stayed in car while car cleaned – assisted cleaning inside of car - not involved in harbouring or disposing of body - no criminal motivation or concerned in any criminal enterprise - no appreciation or understanding of what HS intended.

Assistance to authorities.

Remorse – young immigrant – otherwise good character – excellent rehabilitation prospects.

Singh

(25)

NSWSC [135]

Harrison J

28.2.2012

 

Co-offender:

BHULLAR

Acc after fact to murder

PG

2y 32d

(immediate release)

 

nil

Accompanied principal offender, co-offender and victim in car – victim taken from car by principal offender and killed – remained in car while principal offender washed it – returned in the afternoon to clean inside of car – gave false account to police – replaced tyres on car – in fear of principal offender

Student from poor part of India – good prospects of rehabilitation – good character - assistance

Mackett

(29)

NSWSC [166]

Adams J

7.3.2012

Acc after the fact to murder

VG

3y GBB

(4w PSC)

 

Nil relevant

Female – assisted de facto after he stabbed male in confrontation outside hotel – asked offender’s sister not to tell police he was at hotel - agreed with offender to tell police lie although both subsequently declined to be interviewed – no practical assistance or affect – motivated by relationship - bottom of range

Difficult childhood and adolescence – long history of depression – exceptional hardship on daughters

(Martin [2011] NSWSC 1189)

Hogden

(44)

NSWSC [24]

Davies J

9.3.2012

Acc after fact to murder

 

Sched:
Larceny

PG

FT 18m suspended

 

(197days PSC)

 

minimal

Present when boyfriend strangled female drug dealer in his unit – threats made to offender by boyfriend – assisted in cleaning up unit and moving car – made phone calls to victim’s phone to deflect suspicion – initially lied to police - made voluntary confession to police after body found two months later

Heavy alcohol user

Iskander

(48)

NSWSC [149]

Davies J

16.3.2012

Acc after the fact to murder

VG

2y suspended

 

nil

Husband and son killed offender’s lover in street attack – offender attended scene shortly after attack and told police son was in bed asleep – honestly believed this at the time – subsequently provided son with money and contacted travel agent – assisted son leave the country

Motivated by love for only child – low scale of offending

Purtill

(48)

NSWSC [566]

Harrison J

21.5.2012

Acc after the fact to murder

PG

4y NPP 3y

 

Sexual assault

Assisted younger brother who murdered V by stabbing – V a male acquaintance (not clear why killed) – A knocked on brother’s door to find V killed - cleaned brother’s apartment – drove V’s car away and left it at another location – with brother placed V’s body in canvas bag, drove with brother to location and placed body in shallow grave – used V’s bank cards to withdraw money.

Spontaneous offence – wished to protect brother – used V’s bankcards to pretend V still alive – altruistic actions.

Mid-range objective seriousness – did not stand to gain anything from offence – full immediate confession.

Assistance – to give evidence against brother.

Depression due to losing job and poor financial position – emotionally vulnerable – little prospect of reoffending – remorse and contrition.

Anderson

(23)

NSWSC [1689]

Adams J

5.10.2012

Acc after the fact to murder

 

Sched:

Acc Agg BE&S; 4 x BES

PG

2y GBB

 

nil

Female - A’s boyfriend OH robbed elderly female V during break and enter – V died from loss of blood after hitting sharp drawer edge – A not present at BE but found out later - 8 months pregnant to OH – fled with OH - committed break and enters with OH before and after murder.

Abusive and manipulative relationship with OH - dysfunctional upbringing – gave birth to OH’s child - had second child with another partner – genuine remorse.

Bottom range of objective seriousness.

Serrone

(41)

NSWSC [1232]

RA Hulme J

10.10.12

Acc after fact to murder

VG

5y NPP 3y 6m

 

Supply drugs, possess firearm

V assaulted and killed during planned “drug deal rip-off” by W and others – W convicted of murder – W a manipulative character – A not present and did not at first know of V’s death, A’s involvement commenced after event:- accompanied others to hire car to transport V’s body; proactive in obtaining credit card to hire car; accompanied others to retrieve V’s body; cleaned up at crime scene; conveyed body to W for disposal.

Employed, good character – rehabilitation prospects – good support.

Affected by death of mother - Drug use led to association with W.

Gall & Gall (No.6)

(34)

NSWSC [1432]

Adamson J

23.11.2012

Accessory after the fact

 

Possess proh firearm

Pervert justice

VG

 

 

PG

 

FT 2y

 

Total sentence:

6y

NPP 4y 6m

 

Nil

SNPP 20 years A (BG) accessory to murder by son KG – assisted by washing away blood at scene – KG shot V three times at close range – was previously friends with V however friendship deteriorated badly over drug matter – V had some involvement with bikie gang – V came to V’s property to retrieve property (exact facts not known) – KG planned shooting to get rid of an adversary – buried body in bush.

Smith

(31)

NSWSC [796]

Latham J

3.5.2013

Manslaughter

 

Accessory after fact to murder

 

PG (25%)

Mansl

 

Access after fact to murder

7y

 

12y

NPP 9y

 

Total:

16y

NPP 12y

 

Relatively minor

Failed to obtain medical treatment for 6y daughter of de facto – victim assaulted by mother – after unsuccessful attempts to revive child offender put her to bed and went to work next day – child died during day – body placed in suitcase for several days then placed in shallow grave in bush and burned – gave false accounts of disappearance and laid false trails for over nine months – aware V subjected to long term physical abuse at hands of mother – acted out of loyalty to de facto – manslaughter top of range – accessory worst case

Kaminic

(45)

 

NSWSC [1097]

Latham J

10.5.2013

 

Co-offender:

SAFETLI

GATTELLARI

(murder)

Accessory after the fact

PG

4y 6m

NPP 2y

(50% discount)

 

Nil

Businessman shot dead outside house in front of 9y son – murder ordered by business associate after deterioration of relationship – go-between G and S – concealed gun and passed on payments – just below upper level of objective gravity

Acted almost entirely at behest of G – PTSD from violence suffered in Balkans conflict – major depressive disorder – prison more difficult – high level of assistance

Salas-Collard

(19)

NSWSC [1188]

Adams J

30.8.2013

Accessory after fact to murder

 

Sched:

Accessory after fact to Agg BE

VG

2y GBB

 

minor

Female assisted boyfriend aged 17y – boyfriend and co-offender broke into home of elderly lady at night – victim assaulted with walking stick – two hours later boyfriend and co-offender fatally bashed and stabbed young male stranger on street

Stayed with boyfriend over several days aware he had committed serious offence although not murder – took boyfriend to cousin’s place then friend’s house to evade police

Unstable mental health – emotionally fragile and under thrall of boyfriend – mother to two small children – remorse – unlikely to reoffend

Hamilton

(36)

NSWSC [1209]

Rothman J

30.8.2013

 

Co-offender:
FENNELL

Accessory after fact to murder

PG

(25%)

4y 6m

NPP 3y

 

Record for robbery and violence offences

Assisted in disposal of murder weapon and victim’s car – friend had shot dead victim in attempted robbery of drug dealer – small degree of planning

Acted out of misguided loyalty to female friend

Pintabona

(54)

NSWSC [1328]

RS Hulme AJ

13.9.2013

2 x Accessory after fact to murder

VG

 

Total
4y

NPP 3y

 

 

Husband Di Cianni murdered two victims – DC had stabbed V, former business partner, numerous times – V had defrauded A – also stabbed V2 (brother of V) who lived with V and was home at the time.

A drove D away from crime scene but did not know then that D had committed offences – however later lied to police about D’s whereabouts to conceal crimes.

 

Burns

(31)

NSWSC [1851]

Hidden J

6.6.2013

Accessory after fact to murder

PG

4y

NPP 2y 9m

 

Minor

Female – A in relationship with male V – as relationship soured, A began secret lesbian relationship with L – L shot V so that they could pursue their relationship free from interference by V – Knowing L had shot V, A told lies on a number of occasions to conceal L’s crime – A gave various explanations for V’s disappearance: that he was away working and claimed bikies were chasing V.

Difficult upbringing – mother of two children – major depressive order – remorse.

(Lane [2013] NSWSC 1808)

Estaphan

(20)

[2014] NSWSC 450

Bellew J

30.4.2014

Accessory after fact to murder

 

2 x unauth possess of rifles

PG

(20%)

6y 5m

NPP 4y 10m

 

Total:

6y 7m

NPP 5y

 

 

Male – shooting of businessman McGurk outside home – drove shooter away from scene stopping to allow disposal of gun – involved in burning clothes and stolen number plates – did not disclose involvement to police for 12 months – received substantial amount of money – assisted over significant period of time – present at time of murder – motivated by financial gain as well as association with shooter

Collected and delivered firearms to associate – lower end of scale of seriousness

Genuine remorse – favourable prospects of rehabilitation

Johnson

(39)

[2014] NSWSC 1254

Hamill J

Accessory after fact to murder

PG

(20%)

26m

NPP 18m

 

Minor

Male victim bashed to death by brother – moved body – body not found for 2 years – short period of involvement – confronted with spontaneous offence – fraternal loyalty – brother had been threatened by victim – below mid range

Good character

At [13] summary of relevant factors for accessory sentences

SAFI [2014] NSWSC 1208 (sentence for brother) 

Hunt

(18)

[2014] NSWSC 1919

Button J

​Accessory after fact to murder
​PG

(25%)

​2y 8m

NPP 1y 4m

​Nil adult record
​Female – observed male partner stab victim to death outside house after physical fight – washed knife and cleaned up house – planned false story with partner then lied to police – unplanned and spontaneous

Remorse – aboriginal with deplorable upbringing – 8% future assistance – prospects of rehabilitation

Batcheldor

[2015] NSWSC 1168

Bellew J

​s.86(2)(b)

 

Acc after fact murder

​PG

(10%)

​5y

 

4y 6m

NPP 3y 4m

 

Total:

6y 6m

NPP 5y 4m

​Minor drug offences
​Female - Met with victim and male co-offender at park to discuss stolen property – victim taken to home of third person and detained in garage – period of offender's involvement only one hour - victim later killed by co- offender in absence of offender – in series of acts over several days assisted in arrangements to move body – no direct involvement in moving body and unaware body was incinerated – motivated by loyalty

Genuine remorse – good prospects of rehabilitation

Wran

(26)

[2015] NSWSC 1015

Harrison J

​Rob in Co

 

 

Accessory after the fact murder

​PG

(20%)

 

(25%)

​4y

NPP 2y

 

FT 1y (concurrent)

​Minor
​Female attended unit with two male co-offenders – spontaneous agreement to use threat of force to purchase more drugs than could afford – anticipated possible use of some physical force – waited in lounge room while co-offender forced occupants to bedroom and stabbed them – one died – unaware of presence of knife until entered unit – money and drugs stolen by co-offenders – low objective seriousness

Stayed with male who fatally stabbed victim – boyfriend – for three days failed to report to police – suffering ill health, mental illness and drug addiction – no active concealment or assistance in attempt to escape – aggravated by involvement in robbery – low objective seriousness

Lengthy history of mental illness and drug addiction – good character – genuine remorse – prospects of rehabilitation – continued need for supervision – good support – extra curial punishment from adverse and erroneous publicity – onerous conditions of custody

Stanford

(25)

[2016] NSWSC 1174

​Acc after fact murder
​PG

(25%)

​FT

1y 3m

​Nil
​Brother of VS  - VS abducted and murdered school teacher – VS sent to A the Victim's jewellery rings and driver's licence – A sold rings and burnt licence.

Lower end of range – extent of A's knowledge not clear – A knew that Victim had been abducted and murdered but not how, why or in what circumstances.

Misplaced loyalty to brother - Good prospects rehabilitation - offence committed in a highly specific and unusual context - A has not otherwise demonstrated any tendency to criminal offending.

Manevski (No 2)

(20 at offence, 23 at sentence)

[2016] NSWSC 1465

​Acc after fact murder
​VG

(10% discount for offer of plea of guilty at trial)

​4y 6m

NPP 3y

​Nil
​Female - A's partner stabbed V, young male due to a fight between V and a friend - A spontaneously washed and hid the murder weapon - over an extended period told many lies to police to protect him.

Special circumstances – youth – psychological problems.

Jamieson

(26)

 

[2016] NSWSC 1862

Rothman J

​Acc after fact murder​VG
​4y

NPP 2y

​Violence, assault officer
​Female – AC and HC killed V over drug debt – in a relationship with HC -  killing took place in A's apartment in A's presence - A cleaned apartment with bleach – sought to protect HC and herself.

Slightly above the mid-range objective seriousness.

Difficult background – drug abuse – no remorse – rehabilitation prospects.