Other Assault Offences

CHOKING, SUFFOCATION OR STRANGULATION (NSW OFFENCE)

  1. Choking, suffocating or strangulation is an offence under section 37(1) of the
    Crimes Act 1900 (NSW).
  2. This offence is a Table 1 (T1) offence. It can be dealt with in either the Local Court or the District Court.
  3. The maximum penalty is 10 years imprisonment, however if dealt with in the Local Court the maximum penalty is 2 years imprisonment.
  4. If you plead guilty, or are found guilty, a number of different sentences can be imposed. It is possible that a criminal conviction will be recorded.

If you have been charged with choking, suffocating or strangulation under section 37(1) of the Crimes Act, the prosecutor must prove that you:

  1. intentionally choked, suffocated or strangled another person (the complainant)
  2. recklessly caused the complainant to become unconscious, insensible or incapable of resistance.

Note:

There are two other offences relating to choking, suffocating or strangulation. One is more serious; one is less serious.

If police allege that you intentionally choked, suffocated or strangled the complainant without their consent, police may charge you with an offence under section 37(1A) of the Crimes Act. This offence is less serious because the prosecutor does not need to prove that your actions caused the complainant to become unconscious, insensible or incapable of resistance. It has a maximum penalty of 5 years imprisonment.

Alternatively, if police allege that you choked, suffocated or strangled the complainant with the intention of committing another serious offence, police may charge you with a more serious offense under section 37(2) of the Crimes Act. This offence has a maximum penalty of 25 years imprisonment.

This page only relates to an offence under section 37(1) of the Crimes Act.

What is choking, suffocation and strangulation?

These acts cover an conduct which stops another person from breathing. This can be done by your physical body (i.e. tightly wrapping your hands around someone’s throat) or using an object (i.e. tightening a rope around someone’s throat or covering someone’s head with a plastic bag).

This offence does not include choking, suffocation or strangulation which happens during a lawful activity to which both parties consent, such as wrestling or judo.

How does the court determine whether I intended to choke, suffocate or strangle the complainant?

This is a question for the magistrate or jury, who would consider all of the surrounding circumstances including what you did and said.

What does it mean to be unconscious, insensible or incapable of resistance?

Someone will be unconscious, insensible or incapable of resistance if they are unresponsive or have been overpowered such that they cannot resist the choking, suffocation or strangulation.

What does reckless mean?

In this context, being reckless means that you realised that the complainant may become unconscious, insensible or incapable of resistance by your actions, but continued regardless.

This will depend on a number of factors including, for example:

  • whether you accept that you choked, suffocated or strangled the complainant
  • whether you intended to do so
  • whether the complainant become unconscious, insensible or incapable of resistance (if not, you may still be guilty of an offence under section 37(1A), or common assault
  • whether you were engaging in lawful activity (such as consensual sexual acts).

You may accept that you are guilty of choking, suffocating or strangling the complainant, but disagree with part of what police say happened. In these circumstances, your lawyer may be able to negotiate with the prosecutor to change the police facts.

The court will take into account the nature and seriousness of the assault and the surrounding circumstances.

The court will also take into account many other factors including your personal circumstances and criminal history.

If I plead guilty or am found guilty, will a conviction be recorded?

It is possible that the court may record a conviction. The type of sentence you receive will depend on the facts of your case, your personal circumstances, criminal history and many other factors.

It is important that a lawyer properly prepares and presents your case to minimise the risk of a conviction being recorded.

What does it mean to have a conviction recorded?

A conviction is an entry on your criminal record (also referred to as your antecedents). A conviction may pose a hurdle, or a bar, to current or future employment, travel, adoption, residency, applications for citizenship or your ability to attain or hold a certain licence.

Will I go to gaol for choking, suffocating or strangulation?

Although there are many sentencing alternatives, it is possible that you will go to gaol if you plead guilty or are found guilty.

The maximum penalty is 10 years imprisonment, however the type of sentence you receive will depend on the facts of your case, your personal circumstances, criminal history and many other factors.

KIDNAPPING (NSW OFFENCE)

  1. Kidnapping is an offence under section 86(1) of the Crimes Act 1900 (NSW).
  2. This offence is a strictly indictable (SI) offence. It must be finalised in the District Court, but still commences in the Local Court.
  3. The maximum penalty is 14 years imprisonment. If you have been charged with aggravated kidnapping under section 86(2) of the Crimes Act, or specially aggravated kidnapping under section 86(3) of the Crimes Act, the maximum penalties are higher.
  4. If you enter a plea of guilty, or are found guilty, a number of different sentences can be imposed. It is very likely that a criminal conviction will be recorded. It is also possible that you will be sentenced to a term of imprisonment.

If you have been charged with kidnapping, the prosecutor must prove that you:

  1. took or detained a person (the complainant) without their consent
  2. knew that that the complainant was not consenting, or were reckless to that fact
  3. intended to either:
    1. obtain an advantage
    2. hold the complainant to ransom, or
    3. commit a serious indictable offence.

If you have been charged with one of the more serious kidnapping offences, the prosecutor may also need to prove that you:

  1. were in company of another person(s), or
  2. caused actual bodily harm to the complainant.

What is taking or detaining?

Somebody is taken if they accompany you, or if you have caused them to accompany someone else (i.e. pulling or pushing somebody into a vehicle).

A person is detained if you cause them to stay in a certain place and/or refuse to release them (i.e. locking somebody in a room).

What does consent mean?

Consent involves a conscious and voluntary agreement by the complainant to accompany you, or to stay in a certain place. Consent is not given if the complainant only agrees because of force or threats.

A child (in this context a person under 16 years of age) cannot consent to being taken or detained unless:

  • the person who takes or detains them is their parent, or is someone who is acting with the consent of their parent, and
  • they are not acting in contravention of a court order regarding the child.

What does reckless mean?

In this context, being reckless means that you realised the complainant may not have consented to being taken or detained, but continued regardless.

What is an advantage?

An advantage does not need to be financial. It could include psychological or sexual gratification. The advantage does not need to have been achieved, but it must be proved that you had the intention of achieving an advantage by taking or detaining the complainant.

Whether you took or detained the complainant with the intention of obtaining an advantage is a question for the jury, who would consider all of the surrounding circumstances, including what you did and said.

What is a ransom?

A ransom is a demand to obtain a sum of money for the complainant’s release. It does not matter whether you in fact demanded money, or whether you were successful in obtaining any money. It only has to be proved that you intended to demand a ransom.

Whether you took or detained the complainant with the intention to hold the complainant to ransom is a question for the jury, who would consider all of the surrounding circumstances, including what you did and said.

What is a serious indictable offence?

A serious indictable offence is any offence which carries a maximum penalty of at least 5 years imprisonment. Common examples of serious indictable offences include intimidation and assault occasioning actual bodily harm.

What does ‘in company’ mean?

You will be ‘in company’ if other person(s) were present when you committed the offence, and those person(s) were either:

  • encouraging you
  • ready to assist you if necessary, or
  • also involved in taking or detaining the complainant.

The prosecutor must also prove that there was an express or implied agreement between you and the other person(s) to take or detain the complainant.

What does actual bodily harm mean?

There must be some injury to the complainant. Actual bodily harm (ABH) includes things like bruises, scratches, or marks. The injury does not need to be permanent, but it must be more than transient.

The actual bodily harm must have been caused either at the time of, immediately before or immediately after the complainant was taken or detained.

This will depend on a number of factors including, for example:

  • whether you accept that you took or detained the complainant
  • whether the complainant consented
  • what your intention was.

If you have been charged with one of the more serious kidnapping offences, then you may agree that you took or detained the complainant, but say that you were not in company, or did not cause actual bodily harm to them (in which case you might still be guilty of kidnapping).

You may accept that you are committed the offence you have been charged with, but disagree with part of what police say happened. In these circumstances, your lawyer may be able to negotiate with the prosecutor to change the police facts.

The court will take into account things such as the period of detention, the circumstances of the detention/taking, the characteristics of the person who was detained/taken and the purpose of the detention/taking.

The court will also take into account many other factors including your personal circumstances and criminal history.

If I plead guilty or am found guilty, will a conviction be recorded?

It is very likely that the court will record a conviction. The type of sentence you receive will depend on the facts of your case, your personal circumstances, criminal history and many other factors.

What does it mean to have a conviction recorded?

A conviction is an entry on your criminal record (also referred to as your antecedents). A conviction may pose a hurdle, or a bar, to current or future employment, travel, adoption, residency, applications for citizenship or your ability to attain or hold a certain licence.

Will I go to gaol for kidnapping?

Although there are many sentencing alternatives, it is very likely that you will go to gaol if you plead guilty or are found guilty.

The maximum penalty for kidnapping is 14 years imprisonment. The maximum penalties for aggravated and specially aggravated kidnapping are higher.

The type of sentence you receive will depend on the facts of your case, your personal circumstances, criminal history and many other factors. It is important that a lawyer properly prepares and presents your case to minimise the risk of you going to gaol, or to persuade the court to reduce the length of the gaol sentence.

Could I be guilty of kidnapping a child if I am a relative or family friend?

This will depend if you had the child’s parents’ permission to take or detail the child and whether you intended to hold the child for an advantage, for ransom or to commit a serious indictable offence.

Could I be guilty of kidnapping if I did not actually obtain a ransom?

Yes. What is relevant is whether you intended to detain the complainant in order to demand and obtain a sum of money for the complainant’s release. It does not matter whether you in fact demanded money, or whether you succeeded in obtaining any money.

CHILD ABDUCTION (NSW OFFENCE)

  1. Child abduction is an offence under section 87 of the Crimes Act 1900 (NSW).
  2. This offence is a strictly indictable (SI) offence. It must be finalised in the District Court but still commences in the Local Court.
  3. The maximum penalty is 10 years imprisonment.
  4. If you enter a plea of guilty, or are found guilty, a number of different sentences can be imposed. It is very likely that a criminal conviction will be recorded. It is also possible that you will be sentenced to a term of imprisonment.

If you have been charged with child abduction, the prosecutor must prove that you:

  1. took or detained a child
  2. intended to remove or keep the child from the person(s) with lawful control over them
  3. did not have the permission of the person(s) with lawful control of the child.

What is taking or detaining?

Somebody is taken if they accompany you, or if you have caused them to accompany someone else (i.e. pulling or pushing somebody into a vehicle).

A person is detained if you cause them to stay in a certain place and/or refuse to release them (i.e. locking somebody in a room).

Who is a child?

In this context a child is a person under 12 years of age.

Who has lawful control of a child?

This includes person(s) who are legally responsible for the child at the time they were taken/detained such as parents, legal guardians, carers or school teachers.

This will depend on a number of factors including, for example:

  • whether you accept that you took or detained the child
  • whether you intended to remove or keep the child from the person(s) with lawful control over them
  • whether you had the permission of the person(s) with lawful control of the child to take or detain them.

You may accept that you abducted the child, but disagree with part of what police say happened. In these circumstances, your lawyer may be able to negotiate with the prosecutor to change the police facts.

The court will take into account things such as the period of detention and the circumstances of the detention/taking.

The court will also take into account many other factors including your personal circumstances and criminal history.

If I plead guilty or am found guilty, will a conviction be recorded?

It is very likely that the court will record a conviction. The type of sentence you receive will depend on the facts of your case, your personal circumstances, criminal history and many other factors.

What does it mean to have a conviction recorded?

A conviction is an entry on your criminal record (also referred to as your antecedents). A conviction may pose a hurdle, or a bar, to current or future employment, travel, adoption, residency, applications for citizenship or your ability to attain or hold a certain licence.

Will I go to gaol for child abduction?

Although there are many sentencing alternatives, it is very likely that you will go to gaol if you plead guilty or are found guilty.

The maximum penalty for child abduction is 10 years imprisonment. The type of sentence you receive will depend on the facts of your case, your personal circumstances, criminal history and many other factors.

It is important that a lawyer properly prepares and presents your case to minimise the risk of you going to gaol, or to persuade the court to reduce the length of the gaol sentence.

Could I be guilty of child abduction if I am a relative or family friend of the child?

This will depend if you had the permission of the child’s parents to take or detain the child and whether you intended to remove or keep the child from the person(s) with lawful control over them.

FEMALE GENITAL MUTILATION (NSW OFFENCE)

  1. Female genital mutilation is an offence under section 45(1)(a) of the Crimes Act 1900 (NSW).
  2. This offence is a strictly indictable (SI) offence. It must be finalised in the District Court, but still commences in the Local Court.
  3. The maximum penalty is 21 years imprisonment.
  4. If you enter a plea of guilty, or are found guilty, a number of different sentences can be imposed. It is very likely that a criminal conviction will be recorded. It is also possible that you will be sentenced to a term of imprisonment.

If you have been charged with female genital mutilation, the prosecutor must prove that you excised, infibulated or otherwise mutilated the labia majora, labia minora or clitoris of a person.

A person cannot consent to female genital mutilation, however if the acts are carried out by a surgical operation that is necessary for the health of the person and is performed by a medical practitioner, no offence is committed.

What could amount to excising, infibulating and mutilating?

Any act which involves the injuring or removal of female genitals. This could involve the injuring or removal of the entire genital or simply a part of it.

What is the labia majora, labia minora and clitoris?

These are three of the external female genital organs and are the most visible parts of the vagina.

What are the possible defences?

  • You may deny that you excised, infibulated or otherwise mutilated the labia majora, labia minora or clitoris of a person.
  • You may deny that the part of the body which was excised, infibulated or otherwise mutilated was the labia majora, labia minora or clitoris
  • You may be a medical practitioner who performed a surgical operation which was necessary for the health of the patient.
  • You may be a medical practitioner (or authorised professional) who performed the surgical operation on a person in labour (or who has just given birth), and the operation was for medical purposes in connection with the labour or birth
  • You may be a medical practitioner performing a sexual reassignment procedure

This will depend on a number of factors including, for example:

  • whether you accept that you excised, infibulated or otherwise mutilated the labia majora, labia minora or clitoris of a person
  • whether you are a medical practitioner who performed a surgical operation which was necessary for the health of the patient
  • whether you are a medical practitioner (or authorised professional) who performed the surgical operation on a person in labour (or who had just given birth), and the operation was for medical purposes in connection with the labour or birth
  • whether you are a medical practitioner performing a sexual reassignment procedure.

You may accept that you are committed the offence you have been charged with, but disagree with part of what police say happened. In these circumstances, your lawyer may be able to negotiate with the prosecutor to change the police facts.

The court will take into account things such as the degree of physical injury caused, any ongoing physical or psychological injury, the age of the complainant and the relationship between you and the complainant.

The court will also take into account many other factors including your personal circumstances and criminal history.

If I plead guilty or am found guilty, will a conviction be recorded?

It is very likely that the court will record a conviction. The type of sentence you receive will depend on the facts of your case, your personal circumstances, criminal history and many other factors.

What does it mean to have a conviction recorded?

A conviction is an entry on your criminal record (also referred to as your antecedents). A conviction may pose a hurdle, or a bar, to current or future employment, travel, adoption, residency, applications for citizenship or your ability to attain or hold a certain licence.

Will I go to gaol for female genital mutilation?

Although there are many sentencing alternatives, it is very possible that you will go to gaol if you plead guilty or are found guilty.

The maximum penalty for female genital mutilation is 21 years imprisonment. The type of sentence you receive will depend on the facts of your case, your personal circumstances, criminal history and many other factors.

It is important that a lawyer properly prepares and presents your case to minimise the risk of you going to gaol, or to persuade the court to reduce the length of the gaol sentence.

Could I be guilty of female genital mutilation if the complainant agreed or consented?

Yes. It is not a defence to female genital mutilation that the person consented to the acts.

Further advice:

This blog is intended to provide general information about matters that often come before the court and is not legal advice. For legal advice about this offence or any other criminal offence, please reach out to us and speak to one of our lawyers on (02) 9696 1361 (Sydney) or (02) 5104 9640 (Canberra) or by email at info@hugolawgroup.com.au

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