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AU · Criminal Law

Sentencing submissions workflow

Sentencing is structured discretion. The best submissions walk the court through objective seriousness, subjective circumstances, and the applicable statutory purposes in a way that naturally lands on the proposed range. Preparation is half the outcome.

In short

This is an 8-step workflow for preparing written and oral sentencing submissions in Australian criminal courts after a plea of guilty or a finding of guilt. It applies across local, district, and supreme court sentencing.

Time: 4 to 20 hours depending on the jurisdiction, the seriousness of the offence, and the volume of character and medical material.
Audience: Australian criminal defence lawyers and public defenders preparing submissions on sentence in a local, district, or supreme court matter.
Run this workflow with Quillio — free trial
Prerequisites

Before you start

  • Plea of guilty entered or verdict of guilty returned
  • Statement of facts agreed or narrowed
  • Client instructions on personal history, prospects, and remorse
  • Criminal history (antecedents) obtained
8 steps

The workflow

1

Review the agreed facts

Read the agreed facts against the indictment or court attendance notice. Identify any residual disputes and whether a contested facts hearing is needed before sentence.

Tools: Quillio, Brief of evidence
R v Olbrich [1999] HCA 54
2

Identify objective seriousness factors

Assess where the offending sits on the spectrum for the offence — harm caused, planning, role, vulnerability of victim, breach of trust. This frames the whole submission.

Tools: Quillio
Crimes (Sentencing Procedure) Act 1999 (NSW) s 21A; Sentencing Act 1991 (Vic) s 5
3

Gather subjective material

Collect character references, psychological or psychiatric reports, rehabilitation certificates, employment letters, and any victim-of-crime history. Brief experts where appropriate.

Tools: Report templates, Client intake
4

Apply the sentencing purposes

Work through the statutory purposes — punishment, deterrence, denunciation, rehabilitation, protection of community, recognition of harm — and explain the weighting in this case.

Tools: Quillio
Crimes (Sentencing Procedure) Act 1999 (NSW) s 3A
5

Research comparable sentences

Research recent comparable sentences at appellate and first-instance level. Build a short table of cases with facts, plea, and result to ground the proposed range.

Tools: Quillio, Judicial Commission SNPP
Hili v The Queen [2010] HCA 45
6

Draft written submissions

Draft written submissions with headings — facts, objective seriousness, subjective case, mitigating factors, proposed orders — and attach the character bundle as an exhibit.

Tools: Quillio
7

Prepare client for allocutus

Prepare the client for any allocution or reading of a letter of apology. Rehearse demeanour, tone, and what not to say. Confirm the client understands the range.

Tools: Client conference notes
8

Present oral submissions at hearing

Present oral submissions, tender the character bundle and any reports, and respond to the bench. Close on the proposed orders and any relevant non-parole period.

Crimes (Sentencing Procedure) Act 1999 (NSW) Part 4
Outcome

What you will have at the end

A coherent written and oral sentencing submission that gives the court a clear, evidence-backed path to the proposed orders.

Common issues

  • Character references that read like form letters and carry no weight
  • Psychological reports that do not address causation between condition and offending
  • Running objective seriousness too low in a way that invites a Crown correction
  • Failing to address a statutory aggravating factor head-on
  • Not checking for any mandatory minimum or standard non-parole period
Use with Quillio

Run this workflow on a real matter

Quillio drafts structured sentencing submissions from your facts and subjective bundle, and surfaces recent comparable sentences from appellate databases. See /practice-areas/criminal-lawyers or /free-trial.

General guide only — not legal advice. Sentencing law differs across states and territories; adapt for your jurisdiction and the current legislation.

Try this workflow with Quillio.

Quillio can run this workflow on a real matter, with citations to current AU authority on every step. The free trial requires no credit card.

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