By Thomas Spohr -
Key decisions
- Armstrong v R [2026] NSWCCA 112
- AM v R [2026] NSWCCA 110
Armstrong v R [2026] NSWCCA 112
Sentencing – moral culpability – no need for ‘causal link’
In this, the latest in a line of decisions touching on the topic of moral culpability, the Court of Criminal Appeal (‘CCA’) reviews the authorities and confirms that a ‘causal link’ is not a necessary precondition to mitigation where an offender has suffered serious childhood deprivation.
The applicant was found guilty of sexual offences after a District Court trial and sought leave to appeal his sentence: imprisonment for 6 years and 6 months, with a non-parole period of 3 years and 10 months. He asserted that the sentencing judge had failed to properly determine whether his moral culpability was reduced because of his disadvantaged background, resulting in a miscarriage of justice.
