- Lee v R  NSWCCA 15
- Dean v R  NSWCCA 27
Lee v R  NSWCCA 15
Financial gain as aggravating factor – false identification documents – inherent elements of the offence
The Court of Criminal Appeal (‘CCA’) has found that, unlike certain drug supply offences, profit is not an inherent element of producing identification documents, and in doing so reminded us of how to establish when something is, or is not inherent in an offence.