Watts v The King

[2025] VSCA 283

Victorian Court of Appeal

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Interrogate

Catchwords

1. Criminal Law
2. › Appeal
3. › Sentence
4. › Leave to appeal against sentence
5. › Intentionally causing injury
6. › Excessive self-defence
7. › Whether sentence manifestly excessive
8. › Crimes Act 1958 (Vic), s 18
1. Criminal Law
2. › Sentencing
3. › Procedural fairness
4. › Adverse sentencing findings
5. › Whether finding that offender was carrying a knife was adverse finding requiring notice
6. › Whether finding open on evidence to criminal standard
1. Criminal Law
2. › Sentencing
3. › Manifest excess
4. › Instinctive synthesis
5. › Relevant sentencing factors
6. › Bugmy considerations
7. › Verdins considerations
8. › Koori Court sentencing conversation
9. › General and specific deterrence
10. › Use of bladed weapons

Quick Take

Where a factual matter is raised during a Koori Court sentencing conversation and counsel has an opportunity to address it but does not, a subsequent finding on that matter does not constitute a denial of procedural fairness.

Case Details

Citation[2025] VSCA 283

CourtVSCA

JurisdictionVictoria

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Relies on

Honeysett v The QueenVSCA 214
Leimonitis v The QueenVSCA 198
R v Verdins; R v Buckley; R v VoVSCA 102
Dinsdale v RHCA 54

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