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Key decisions

  • Lee v R [2019] NSWCCA 15
  • Dean v R [2019] NSWCCA 27

Lee v R [2019] 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.

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