Section 23 of the Crimes (Sentencing Procedure) Act 1999 (NSW) is broad enough to encompass assistance provided by an offender who was the victim of the crime about which the assistance was given. However, the majority held that such cases warrant a more limited discount than cases falling within the primary field of operation of s 23. The question of whether s 23 applies to assistance provided before the commission of the offender's own offences remains open.
The full text is available to signed-in members, including the 15 later cases that cite this judgment.
3 of the 15 citing cases carry a classified treatment. How each court treated it is available to signed-in members.