VDH v WA

[2025] WASCA 10

Western Australia Court of Appeal

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Interrogate

Catchwords

1. Criminal Law
2. › Appeal against conviction
3. › Unreasonable verdict
4. › Sexual offences against children
5. › Whether verdicts unreasonable or unsupported by the evidence
6. › Whether inconsistencies and discrepancies in complainant evidence required jury to entertain reasonable doubt
7. › Criminal Appeals Act 2004 (WA), s 30(3)(a)
1. Criminal Law
2. › Sentencing
3. › Sexual offences against children
4. › Totality principle
5. › Whether total effective sentence bore proper relationship to overall criminality
6. › Whether sentence was crushing having regard to offender's age
7. › Criminal Code (WA), s 320(2), s 320(4)

Quick Take

In cases involving allegations of historical child sexual abuse, gaps and fallibility in complainant recollection on matters of detail after decades are to be expected and do not of themselves render verdicts unreasonable; a 'perfect' recollection would invite greater misgivings.