The case applies the established framework under the Dangerous Sexual Offenders Act 2006 (WA) to a serial sexual offender with entrenched deviant sexual fantasies and multiple failed treatment programmes. The court confirmed that where the most significant risk factor (sexual fantasy life) has not been modified by treatment and the offender has demonstrated an ability to adjust behaviour to accommodate supervision conditions while still pursuing offending, no supervision order conditions can adequately reduce the risk, requiring indefinite detention. The possibility of andropause reducing risk was insufficient where the only evidence was the offender's self-report, contradicted by evidence of a continuing active sexual fantasy life.
The full text is available to signed-in members, including the 33 later cases that cite this judgment.
4 of the 33 citing cases carry a classified treatment. How each court treated it is available to signed-in members.