CHAPTER 2

CHAPTER 2

Key issues

2.1        This chapter discusses the following key issues raised during the inquiry:

Age and people smuggling prosecutions

Prosecution policies

2.2        The age of suspected offenders and the affect of this factor on prosecutions for people smuggling offences was an area of focus during the committee's inquiry. The Prosecution Policy of the Commonwealth outlines a number of factors to which regard should be had '[i]n determining whether or not the public interest warrants the prosecution of a juvenile'.[1] In particular, these factors include the seriousness of the alleged offence, and the age and apparent maturity and mental capacity of the juvenile.[2] AGD has previously outlined that, in accordance with this policy, the CDPP will not, in most circumstances, prosecute persons who are found to be juveniles at the time of the alleged people smuggling offences.[3] The Commonwealth joint submission confirmed that minors would only be prosecuted for people smuggling offences in exceptional circumstances:

In the absence of exceptional circumstances, and provided the person has not sought to engage Australia's protection obligations, if a person is assessed by an agency or determined by a court to be a minor, the person is returned by DIAC to their country of origin without charge.[4]

2.3        In relation to x-ray age assessment procedures, the Commonwealth joint submission outlined:

An investigating official may only arrange for the carrying out of a prescribed procedure [such as a wrist x-ray] where the person is suspected of a serious Commonwealth offence, and it is necessary to establish the age of the person for criminal justice purposes, such as determining the applicable investigatory safeguards, the appropriate court and detention facilities, and whether any mandatory minimum penalties apply. During the investigation and prosecution stages, if a person's age is in dispute and there is insufficient evidence to establish that the person is an adult, the person is given the benefit of the doubt about their age and treated as a minor.[5]

2.4        At the public hearing, an officer from AGD confirmed that age assessment procedures have been 'continually under review' and a further change to procedures was made in December 2011. Under the change, the initial DIAC assessment that a person on a people smuggling vessel is a minor will be accepted by authorities and the person will usually be repatriated without referral to the AFP for investigation. Only if DIAC considers a person to be an adult will a person be referred to the AFP for investigation.[6] An officer from the AFP noted that this changed procedure means, in practice:

If a person is referred to us, the only time we would now conduct a wrist
x-ray would be if, when the person was referred to us, we believed them to be an adult and, subsequently, they claimed to be a juvenile. That may be post charge; it may be pre charge. It depends when they raise that claim with us.[7]

Mandatory sentencing

2.5        The relationship between claims by persons suspected of people smuggling to be children, and the mandatory minimum penalties for some people smuggling offences, was also raised by submitters as significant issue.[8] Currently under the Migration Act, a number of aggravated people smuggling offences attract mandatory minimum penalties.[9] However, these mandatory minimum penalties do not apply if it is established 'on the balance of probabilities' that the person was aged under 18 years when the offence was committed.[10] Further, a court may discharge an offender without proceeding to conviction in respect of a charge for an aggravated people smuggling offence 'only if it is established on the balance of probabilities that the person charged was aged under 18 years when the offence was alleged to have been committed'.[11]

2.6        In its submission, the Migrant and Refugee Rights Project at the University of NSW highlighted the low threshold for the aggravated people smuggling offence in section 233C of the Migration Act:

The only "aggravating" factor that differentiates this offence from the standard smuggling offence...is the element that five or more noncitizens were brought to Australia. Because unauthorised boats invariably carry five or more people, all defendants are charged with this "aggravated" offence and liable for the mandatory five year sentence – regardless of their personal circumstances, level of involvement or moral culpability.[12]

2.7        The Migrant and Refugee Rights Project emphasised the serious consequences of the mandatory minimum penalties for children where they may have been incorrectly assessed by authorities to have been adults at the time of aggravated people smuggling offences.[13] However, as was noted by the Australian Human Rights Commission, mandatory minimum penalties also 'may be an incentive for an individual under investigation...who is aware of this policy to make a false claim to be a child'.[14]

Skeletal age assessment (wrist x-ray)

2.8        As outlined in Chapter 1, the use of x-rays to examine the hand of a person to assess age has been a prescribed procedure for age determination in Australia since 2001. An x-ray is a non-invasive medical procedure which exposes a part of the body to a dose of radiation in order to produce a picture of that part of the body. The examination and analysis in relation to age assessment involves an x-ray being taken of the hand, usually the left hand and wrist, after which a comparison is made against a standard atlas of skeletal age to assess skeletal maturity.

2.9        The Greulich Pyle method (GP method) is the most common method for determination of skeletal maturity.[15] This method compares the x-ray to the radiographic 'atlas', which is a body of x-ray images of wrists of children of different ages. The standards were developed by William Gruelich and Sarah Pyle throughout the 1930s and 1940s in the United States, using x-rays of the hands and wrists of American children of northern European descent.[16]

2.10      The committee previously considered the use of wrist x-rays for age determination in its inquiry into the Crimes Amendment (Age Determination) Bill 2001 (2001 Bill). The committee acknowledged that the GP method 'is now seen as somewhat outdated' and that it is a reversal of 'the usual process in which the chronological age is known and the procedure is used to assess bone age and any delays or advance that may be caused by health problems'.[17] The committee also determined that the accuracy of the technique could not be assured:

Although the wrist x-ray is intended to demonstrate the extent of fusion of two bones, there is no real correlation between bone age and chronological age. Variations can be as much as more than a year higher than chronological age, and up to 18 months younger than chronological age.[18]

2.11      Nonetheless, the committee concluded that the provisions of the 2001 Bill 'may assist in clarifying the age of some persons suspected of, or charged with, Commonwealth offences' and recommended that the 2001 Bill be passed with some amendments.[19]

Concerns about the use of wrist x-rays

2.12      A number of submitters and witnesses to the current inquiry criticised or raised concerns with reliability of the use of wrist x-rays and the GP method to determine the age of alleged people smugglers.[20] For example, the Royal Australian and New Zealand College of Radiologists (RANZCR) supported the Bill's amendments to remove 'any possibility of taking an x-ray of a person's body part as a prescribed procedure for age determination'. It argued that there is 'overwhelming evidence that bone age estimation is too inaccurate to be used for determining chronological age for legal reasons', noting that recently 'radial differences have been shown in Middle Eastern, Asian and Black American populations with bone age disparities between 6 to 12 months depending on the age when the children were assessed'.[21]

2.13      The paper provided to the committee by Professor Sir Al Aynsley-Green Kt highlighted the many practical complications with age assessment and stressed that there is no scientific method to accurately determine the precise chronological age of a person.[22] In the paper, he observed:

There has been overwhelming professional opposition to the use of radiology in the UK on the basis of being inaccurate, not designed for purpose, unethical and potentially unlawful; this has forced government to abandon its proposal that they should be used.[23]

2.14      Professor Tim Cole provided the committee with a lengthy submission dealing with the statistical issues of using the GP method to determine chronological age. He concluded that 'there are no useful markers of physical maturity that can be used for forensic age assessment'.[24]

2.15      The Australian Human Rights Commission summarised a number of the concerns of 'medical and other experts' regarding the use of wrist x-rays for age assessment purposes.[25] These include:

2.16      The Australian Human Rights Commission acknowledged that wrist x-rays have been used, in some instances, to determine that a person suspected of people smuggling offences was a child and to facilitate the quick return of that child to Indonesia. Nonetheless, it would be 'seriously troubled' if x-rays were being relied on as 'sufficient evidence of themselves to establish that any individual is an adult'.[27]

No prohibition of wrist x-rays

2.17      Despite concerns regarding the accuracy of wrist x-ray age assessments, the Migrant and Refugee Rights Project, Victoria Legal Aid and Legal Aid NSW considered that the Bill should not prohibit the use of x-rays to assess age.[28] The Migrant and Refugee Rights Project argued:

In our opinion, it is not necessary (and indeed it is unusual) to prohibit reliance on a particular form of evidence. However given the unreliability of the x-ray technique, we recommend that the Bill instead prohibit age determination on the sole basis of x-rays. We support the examples of additional forms of evidence under [proposed new subsection] 3ZQAA(5) ('birth certificates, affidavits from family members of the person, school records and medical records').[29]

2.18      Legal Aid NSW supported abolition of regulation 6C of the Crimes Regulations 1990 but not a ban on the use of wrist x-rays in age determination:

[T]he existence of the Regulation appears to have had the effect of giving more credence to the use of wrist x-rays as a means of determining age, the corollary of which has been a reliance by both the prosecution and some courts on the use wrist x-rays as the most valid means of determining age... On the other hand we are aware that a number of Indonesian children have been sent home very soon after an x-ray was conducted. For this reason, we would not support an outright ban on the use of wrist x-rays as a means of determining age as in some cases it is to the child's advantage, as it can ensure an early release from detention.[30]

Commonwealth joint submission

2.19      The Commonwealth joint submission dismissed a number of the concerns raised in relation to the GP method of age assessment. It pointed out that there are 'a number of studies and papers that validate the Greulich and Pyle Atlas across racial and ethnic groups' and that '[b]ased on expert advice the Commonwealth has sought, a wrist x-ray procedure can assist in determining whether a person is 19 years or older as male wrist skeletal maturation occurs on average at that age'.[31]

2.20      At the committee's public hearing, an officer from AGD acknowledged that age assessment is an inexact science which involves a margin of error and that x-ray analysis of age might be affected by socioeconomic factors. However, the officer suggested that 'wrist x-rays and other measures of age, while not individually conclusive, in combination play a valuable role in the age determination process'.[32] In summary:

[T]he government considers that the use of x-rays as part of the matrix of methods used to assess age is justified. It results in law enforcement agencies and the courts being able to make informed decisions about the age of a person claiming to be minor when there is doubt about that claim...[33]

2.21      The Commonwealth joint submission also noted that, during the investigation and prosecution stages, 'if a person's age is in dispute and there is insufficient evidence to establish that the person is an adult, the person is given the benefit of the doubt about their age and treated as a minor'.[34] The Commonwealth joint submission emphasised that '[w]hile a wrist x-ray that indicates the person is a minor results in the discontinuance of criminal proceedings (other than in exceptional circumstances), a wrist x-ray that indicates the person is an adult is not determinative'.[35]

2.22      An officer from the CDPP explained, that when x-rays are used in the prosecutions of people smuggling offences, it is not suggested that they 'prove' the defendant is over 18 years of age:

We have attempted to assist the courts by giving them some indication of what the probabilities are, and at the end of the day...wrist x-rays are not a perfect system; they are just one indicator....It is then a matter for the court to assess that evidence, together with any other evidence it has, and decide whether it is satisfied that the person is over the age of 18 or not.[36]

2.23      The Commonwealth joint submission rejected the proposed amendments in the Bill regarding x-rays utilised for age determination. In particular, 'removing x-ray procedures would eliminate both the scientific basis for determining age and the ability to conduct quick age assessments, potentially to the detriment of the defendant'.[37] Further:

Given the ramifications of age determination outcomes for individuals, and the large number of cases to date which have not proceeded on the basis of a wrist x-ray indicating that the suspect is a minor, the Commonwealth considers that concerns over the reliability of x-ray technology are outweighed by the need for all available evidence to be presented to the court.[38]

2.24      The Commonwealth joint submission also indicated that, if skeletal X-rays are removed as an age determination procedure, the AFP and the CDPP would have to rely on interviews and information collected from the person's country of origin. However, 'gathering evidence using these methods can be a lengthy process, and unachievable in the proposed timeframes for age determination'.[39]

2.25      In relation to the commencement of the Bill's proposed amendments, the Commonwealth joint submission also informed the committee that 'removing the ability to use x-ray evidence already obtained could cause delays in current cases where x-ray analysis is likely to be key evidence in determining the age of the person, whether as a minor or an adult'.[40]

Dental age assessment (wisdom tooth)

2.26      The merits of dental age assessment were also considered in submissions to the inquiry. This procedure usually involves taking an orthopantomogram, an x-ray of the person's jaw and teeth. Conflicting evidence was received in relation to the forensic value of dental age assessment. In the view of the Australian Society of Forensic Odontology, analysis of third molar (or wisdom tooth) development from an orthopantomographic image assessment is sufficiently correlated with chronological age to be of forensic value:

The assessment of the development of the third molar provides an ideal means to discriminate between an adult and a child. Third molars develop from midteens to early 20s and complete closure of the apices of the third molar teeth is an indication that the living individual is over the age of 18 years and thus, by definition, an adult.[41]

2.27      However, Professor Tim Cole argued that 'dental age assessment raises the same issues as bone age assessment, notably a dose of radiation, uncertainty in the age of maturation, and a bias against individuals whose maturation is advanced'.[42] Similarly, the Royal Australasian College of Physicians contended that there is 'insufficient evidence to conclude that dental x-rays are accurate'.[43] Professor Michael Ditchfield, Chair of the Paediatric Imaging Reference Group from the Royal Australian and New Zealand College of Radiologists (RANZCR) noted that dental disease and poor dental hygiene will also affect the assessment of teeth with respect to skeletal age.[44]

2.28      The Commonwealth joint submission suggested that there could be increased use of dental x-rays for age assessment in the future:

In addition to introducing a suite of improved age assessment measures in mid-2011, including offering voluntary dental x-rays and interviews, the Commonwealth is also considering adding dental x-rays as a prescribed procedure in the Crimes Regulations. This would allow investigating officials to seek an order from a court to conduct a dental x-ray and subject them to the same procedural safeguards as wrist x-rays.[45]

2.29      An officer from the AFP informed the committee at the public hearing that, between 8 July 2011 and 15 March 2012, 24 persons accused of people smuggling had been offered voluntary dental x-rays for the purposes of age assessment, but none had accepted.[46] NSW Legal Aid also commented that, while the CDPP has previously offered dental x-rays as an alternative to wrist x-rays, '[t]his has generally been rejected by clients on the advice of defence lawyers as the information we have obtained has been that this methodology has similar problems to wrist x-rays, in terms of unreliability and health risks'.[47]

Ethical issues

2.30      Ethical issues were also raised in relation to health professionals performing medical procedures for the purpose of determining age.[48] For example, RANZCR considered that it is 'unethical to expose a young person to radiation for purely administrative reasons'.[49] Professor Michael Ditchfield from RANZCR noted:

[T]he radiological procedures performed in Australia and throughout the world are largely governed by the ALARA principle. ALARA stands for 'as low as reasonably achievable' and refers to the radiation dose...The basis of ALARA is that radiation, no matter what the dose, is harmful; and if there is no clinical benefit to an examination it should not be performed.[50]

2.31      The Australian Society of Forensic Odontology also acknowledged the 'medico-ethical and legal considerations involved in conducting radiological procedures' on living people with no defined medical benefit.[51] It considered that fully informed consent by the patient to the procedure is vital:

Comprehensive age assessment of living individuals necessarily involves the use of ionising radiation – x-rays – with unavoidable radiation exposure. While this exposure is not at a level sufficient to cause immediate harm, it does raise the total lifetime dose of radiation experienced by the individual.[52]

2.32      The Commonwealth joint submission outlined that it had received expert advice that radiation exposure from wrist and dental x-rays is minimal. The Commonwealth's view is that 'the health risks associated with wrist x-rays are outweighed by the serious consequences to the individual, and the criminal justice system more broadly, of an age determination made on the basis of insufficient evidence'.[53]

2.33      The paper provided by Professor Sir Al Aynsley-Green Kt noted that new methods, including magnetic resonance imaging and ultrasound studies of bones, could overcome 'ethical objections to inflicting x-rays for administrative purposes' but that these techniques are likely to face similar problems regarding accurate age assessment.[54]

Multidisciplinary age assessment

2.34      Some support was expressed in submissions, and by witnesses, for taking a multidisciplinary or holistic approach to age assessment in Australia, including obtaining identification material from the person's place of origin.[55] For example, the Royal Australasian College of Physicians considered that there is room to investigate alternative methods of age assessment and suggested 'comprehensive assessments which may include psychological, cognitive, developmental and cultural factors'.[56] Further, 'there is still a need for some form of age assessment in the criminal justice system'.[57]

2.35      Similarly, RANZCR recommended the development of a 'holistic' age assessment process, incorporating 'narrative accounts, physical assessment of puberty and growth, and cognitive, behavioural and emotional assessments'.[58] However, Professor Michael Ditchfield from RANZCR considered that wrist x-rays are too inaccurate to be part of a holistic age assessment process, noting that age assessments will be wrong 'at least one in five times'.[59]

2.36      Dr Jill Benson AM considered that, '[g]iven that the 'science' of age assessment is inexact, it is important that the narrative account, the parent's story of the time and circumstance of the child's birth and developmental milestones, is clearly documented as this is the most likely means of properly assessing the age'.[60] Similarly, Mr Saul Holt of Victoria Legal Aid described an 'emerging consensus' on the importance of holistic age assessment and stressed that this should be combined with 'genuine inquiries in the local community of family members, friends, teachers and village chiefs'.[61] Ms Bassina Farbenblum from the Migrant and Refugee Rights Project considered that the onus of collecting this type of information should be on the Crown, rather than the defendant or legal aid organisations.[62]

2.37      The Commonwealth joint submission emphasised that wrist x-rays are not considered determinative in isolation:

[I]nvestigating officials use a suite of methods to assess a suspect's age, including offering voluntary dental x-rays, voluntary interviews, and obtaining documents from the person's country of origin (such as birth certificates, school records and statements from relatives).[63]

2.38      However, in considering the age determination procedures used overseas, the Commonwealth joint submission pointed out that there is no authoritative definition of a 'holistic approach to age determination'. Wrist x-rays are still used in a large number of European countries as part of age assessment procedures and, further, 'the holistic approach to age determination in the UK does not appear to have resulted in fewer disputes about age'.[64]

2.39      At the public hearing, an officer from the AFP noted the limitations of documentation detailing age in Indonesia, in particular highlighting estimates that only 55 per cent of Indonesian births were recorded between 2000 and 2008.[65] In relation to information gathered through interviews, the AFP officer noted that 'typically the majority of Indonesia crew decline to participate in a formal record of interview with police'.[66] He also outlined that the AFP had sought advice from a social anthropologist who had advised that it is not feasible to develop a generic set of age assessment interview questions, due to the diversity of the Indonesian language, culture and geography. The officer stated that the AFP is 'now exploring other enhanced interview techniques to use in the event individuals accept [its] offer of interview'.[67]

Burden and standard of proof

2.40      Several submissions focused on the appropriate evidentiary standards for age determinations by courts. The Commonwealth joint submission noted that, currently if a person continues to raise age as an issue after being charged, a court makes 'a determination on the balance of probabilities about whether the person is a minor'.[68]

Burden of proof

2.41      While courts generally attribute the onus of proof to the prosecution, the Commonwealth joint submission noted that this issue has been dealt with inconsistently. In order to create consistency between the courts in each jurisdiction, 'the Commonwealth is considering possible amendments to the Migration Act to expressly provide that, where a defendant raises the issue of age during proceedings, the prosecution bears the legal burden to establish the defendant was an adult at the time the offence was committed'.[69]

2.42      Victoria Legal Aid also highlighted that the Migration Act does not make explicit who bears the onus of proof in establishing age, and the law in other states and territories appears unclear on this point. In Victoria, only one age determination hearing in a people smuggling prosecution case has been finalised ‑ in that case, the prosecution conceded that the Crown bore the onus of proof for the purpose of the hearing.[70] Similarly, Legal Aid NSW supported the amendment in proposed new subsection 3ZQAA(2) to place the burden of proof on the prosecution to disprove the person's claim that they are under 18 years of age. It argued that the present position of the law is unclear as to who bears the onus of proof and that a statutory provision would clarify the law.[71]

Standard of proof

2.43      Some submissions considered that the significant implications of an inaccurate age determination suggest that the standard of proof should be 'beyond reasonable doubt' rather than 'on the balance of probabilities'. For example, the Migrant and Refugee Rights Project commented:

[I]n light of the serious irremediable harms that inevitably result from erroneous classification of a child as an adult in this context, and the problems with x-ray evidence, we recommend that proposed s3ZQAA(4) be amended to require the prosecution to prove beyond a reasonable doubt that the person was 18 years or over at the time of the offence.[72]

2.44      In relation to proposed new subsection 3ZQAA(4), Legal Aid NSW also recommended that the standard of proof needs to be 'beyond reasonable doubt, not proof on the balance of probabilities'.[73] It advised that '[t]he experience in NSW has been that in court wrist x-rays have been accepted over concerns about reliability, and over concerns about statistical problems, because courts only need to be satisfied on the balance of probabilities'.[74]

2.45      However, an officer from the CDPP commented:

I think it would be very difficult to establish to that standard that somebody is definitely over the age of 18 beyond any reasonable doubt—just looking at the sorts of evidence we have had, because it can vary. There might be cases where you have documentary evidence which can be substantiated in a number of ways, so that you might be able to get there, but certainly our experience has been that in these particular cases it is very difficult to get documentary evidence or objective evidence to that standard.[75]

International law and human rights

2.46      Examples of the treatment of persons charged with people smuggling offences who were later found to be children at the time of the alleged offences were highlighted in a number of submissions. For example, Victoria Legal Aid outlined that their clients spent an average of 6.9 months in immigration detention before being charged, and spent an average of 9.3 months in immigration detention and prison before having their charges withdrawn. One client spent 16 months in detention and prison before people smuggling charges were ultimately withdrawn.[76]

2.47      A large number of submissions highlighted the importance of compliance with Australia's obligations under the United Nations Convention on the Rights of the Child (CRC).[77] In general, these submissions perceived the amendments proposed by the Bill as enhancing Australia's compliance with the CRC and other international human rights obligations of Australia. For example, the Western Australian Commissioner for Children and Young People, Ms Michelle Scott, noted:

The [CRC] sets out a number of articles under which children, defined as persons under the age of 18 years, are entitled to special treatment, assistance and protection due to their vulnerability to abuse and exploitation. The CRC specifies that all decisions in relation to children should give primary consideration to the best interests of the child. Other specific articles set out in the CRC are also of relevance in this matter, particularly article 37 which contains provisions relating to the detention of children. Article 37 requires state parties to ensure that children deprived of their liberty are only done so as a measure of last resort and for the shortest possible time. Where children are held in detention they should be able to access legal advice and other support and, where appropriate should maintain contact with their family. Children should also be separated from adults whilst in detention unless it is not in the child's interest to do so.[78]

2.48      The Human Rights Law Centre also noted that article 37(c) of the CRC expressly includes a requirement that 'every child deprived of liberty shall be separated from adults unless it is considered in the child's best interest not to do so'. It argued that 'detention of foreign-national children in Australian adult prisons is a clear breach of Australia's obligation under the CRC' and that the Bill's amendments would assist Australia to meet its human rights obligations.[79]

2.49      Several submissions also noted the commentary of the United Nations Committee on the Rights of the Child (UNHRC) in relation to identification and age determination of children:

Prioritized identification of a child as separated or unaccompanied immediately upon arrival at ports of entry or as soon as their presence in the country becomes known to the authorities (art. 8). Such identification measures include age assessment and should not only take into account the physical appearance of the individual, but also his or her psychological maturity. Moreover, the assessment must be conducted in a scientific, safe, child and gender-sensitive and fair manner, avoiding any risk of violation of the physical integrity of the child; giving due respect to human dignity.[80]

2.50      Other submissions drew attention to Australia's obligations under the International Covenant on Civil and Political Rights (ICCPR).[81] For example, the Migrant and Refugee Rights Project noted that the 'incarceration of children in adult correctional facilities violates Australia's obligation under the ICCPR to ensure that accused juveniles are separated from adults in prison (article 10(2b))'.[82] The Migrant and Refugee Rights Project also considered that holding persons suspected of people smuggling offences 'in immigration detention for arbitrarily long periods of at least several months' before being charged also violates Australia's obligations under the ICCPR (articles 9(1), 9(2), 9(3) and 24(1)).[83]

2.51      The Commonwealth joint submission acknowledged the obligations of Australia under both the CRC and the ICCPR[84], and outlined the practices and approaches of Commonwealth agencies in dealing with minors in accordance with these international law and human rights obligations. In relation to age determination:

The Commonwealth aims to ensure that age determination of a person is made at the earliest possible stage. In conformity with the views of the Committee for the Rights of the Child, Australian authorities take into account a range of considerations for borderline cases, including a person's claim about age, the physical appearance of the individual, as well as his or her psychological maturity. In the event of remaining uncertainty about the person's age, the individual is given the benefit of the doubt that he or she is in fact a minor.[85]

Commentary on specific proposed amendments in the Bill

Time limit on age determinations

2.52      Some submissions welcomed the proposed amendments in the Bill that would require 'authorities to accurately determine the age of a suspected minor and to do so within a defined and short timeframe'.[86] However, the Commonwealth joint submission highlighted a number of practical problems with the 30 day time limit proposed in the Bill for an investigating official to make an application to a magistrate challenging a person's claim about age after he or she has been taken into immigration detention. In particular, it raised concerns regarding:

2.53      Similarly, while the Human Rights Law Centre welcomed the Bill's proposed clear and confined time limits:

[T]he need for expediency must be balanced against fairness in the age determination process. Extensions of time may be necessary in some cases to enable the investigating authorities to obtain appropriate evidence of the suspect's age...[88]

2.54      Legal Aid NSW also did not support the proposal in the Bill for age determinations to be made before magistrates and not judges. It recommended that proposed new section 3ZQAA(2) be amended to include a 'magistrate or judge'[89] because:

The proposal would have the unintended consequence of preventing age determination applications being made to District Court judges, as this Bill refers only to an application before a 'magistrate'...District and County Courts...are staffed by judges much more experienced in hearing complex expert evidence and in discerning between competing claims to scientific expertise.[90]

Youth justice facilities

2.55      Several submissions supported the proposed amendment in the Bill that persons claiming to be under the age of 18 should be placed in a 'youth justice facility' until their age is determined. [91] For example, the Human Rights Law Centre argued that it is 'entirely inappropriate for children, or persons claiming to be children, to spend long periods of time in either immigration detention or prison facilities while awaiting formal charges or age determination hearings'.[92]

2.56      However, the Commonwealth joint submission highlighted concerns with the proposal, including that 'youth justice facility' is not currently a defined term in the Crimes Act or the Bill. Further:

The rules governing the detention of minors in each State and Territory are not uniform. As such, any definition of the term 'youth justice facility' will require State and Territory consultation.[93]

2.57      The Commonwealth joint submission opposed the 'presumption of age' in Item 3 of Schedule 1 of the Bill, arguing that it could lead to adults being placed in 'youth justice facilities':

The effect of item 3 is that a person, regardless of their physical appearance or any documentary evidence of their age, could claim to be a minor and would have to be treated as such, including being remanded to a 'youth justice facility'...Until the magistrate makes an order, investigating officials would be required to detain the person in the youth justice facility with other minors.

Where the person makes a late claim about age and the 30 day time limit for age determination has expired, or is about to expire and there is insufficient time to collect evidence of the person’s age, there is no recourse to challenge the person's claim. It is not clear in these circumstances how the criminal proceedings would be dealt with.

The Commonwealth considers it inappropriate that the administration of justice should be affected on the basis of a person's claim alone, particularly where there are significant incentives for making the claim, such as avoiding mandatory minimum penalties. More importantly, a presumption of age creates a serious risk for other minors detained in youth justice facilities, where the person claiming to be a minor is an adult.[94]

2.58      The Australian Human Rights Commission recommended that 'proposed s 15(2) of the Bill be amended to ensure that there is a presumption that an individual awaiting trial for people smuggling offences who has been determined to be a minor or who asserts that he or she is a minor be granted a Criminal Justice Visa and be released on bail with appropriate conditions'.[95]

2.59      The Commonwealth joint submission noted that in 'both immigration and criminal justice contexts, where a person claims to be a minor but the available evidence indicates the person is an adult, the interests of the person are balanced carefully against the interests of other minors in determining appropriate housing arrangements'.[96] The CDPP generally does not oppose bail for persons charged with people smuggling offences claiming to have been a minor at the time of the offence. Where bail is granted, the person is returned to immigration detention to be housed in an appropriate facility for minors.[97]

Time limit on bringing people smuggling charges

2.60      Several submissions broadly supported the Bill's proposed 14-day time limit for charging persons suspected of people smuggling offences who are (or claim to be) under 18 years of age. For example, the Australian Human Rights Commission indicated that it would welcome 'the establishment of limits...on the time taken to bring charges against a non-citizen in criminal proceedings relating to people smuggling offences'.[98]

2.61      Victoria Legal Aid strongly supported the establishment of statutory time limits for the laying of people smuggling charges. In the view of Mr Saul Holt these are 'extraordinarily simple prosecutions' where persons of Indonesian origin on vessels with asylum seekers arriving in Australian waters are 'obviously prima facie likely to be charged with people smuggling offences'.[99] Mr Holt argued that the early laying of charges against accused people smugglers 'should not hamstring the AFP' and would mean accused people smugglers are under the supervision of a court and entitled to legal representation:

[O]ur view is that it is better for that person to be subject to a charge and therefore be under the supervision of a court and have access to legal advice than to be held in immigration detention limbo for lengthy periods of time before age determination is resolved.[100]

2.62      However, the Commonwealth joint submission highlighted that the Bill would be inconsistent with subsection 15B(1) of the Crimes Act, which provides that 'a prosecution may commence at any time for a Commonwealth offence that carries a maximum penalty of imprisonment for six months or more for a first conviction'.[101] The proposed 14-day time limit would have 'serious consequences for the administration of criminal justice, the independence and effectiveness of investigating officials, and may undermine the Commonwealth's ability to conduct people smuggling prosecutions'.[102] Additionally, the Commonwealth joint submission considered that the Bill's proposed time limit would not be 'operationally' feasible because of the practical delays and challenges for the AFP in gathering evidence and investigating people smuggling offences.[103] These include certain legislative requirements, limited numbers of qualified interpreters, and a reliance on foreign law enforcement authorities for the collection of evidence.[104]

2.63      At the public hearing, an officer from the AFP noted that the AFP benchmark for average time in detention between interception of a people smuggling vessel and charging a people smuggling suspect is 90 days. However, the officer noted that currently 'on average, it is 104 days between intercept and change'.[105]

Committee view

2.64      The Bill has highlighted many of the complex obstacles facing Australian authorities in relation to age assessments and the periods of detention which persons accused of people smuggling offences may face while assessments and determinations are made regarding their age. The lack of an accurate scientific method of age determination presents a significant challenge in relation to the prosecutions of persons who may have been underage at the time of people smuggling offences. Further, Australia's policies and protections for children mean that there are incentives for adult people smugglers to falsely claim to be underage. As Victoria Legal Aid noted, these prosecutions 'give rise to genuine competing public policy considerations'.[106]

2.65      In this context, the committee anticipates that the recent procedural changes made by the Australian Government in relation to age assessments for persons intercepted on people smuggling vessels, implemented after the Bill's introduction and referral to the committee, will help ensure that those who are underage will be promptly returned to their country of origin. Following this procedural change in December 2011, persons on a people smuggling vessel are only to be referred to the AFP for investigation if DIAC assesses the person to be an adult. Accordingly, the committee does not consider that the proposed amendments in the Bill are an appropriate solution in addressing the challenges inherent in prosecutions for people smuggling offences where the accused might have been a child at the time of the alleged offence.

2.66      Currently, only x-rays of the hand and wrist are a prescribed procedure for determining age under the Crimes Regulations 1990. However, the committee notes that courts may take into account a broad range of evidence in making a determination regarding a person's age. Recent announcements by the Australian Government mean that voluntary dental x-rays and interviews to assess age are now also available to those persons accused of people smuggling offences who claim to be children. In this context, the committee acknowledges that the Australian Government is considering adding dental x-rays as a prescribed procedure under the Crimes Regulations.[107]

2.67      While the committee acknowledges the limitations of wrist (and dental) x-rays in assessing age, it does not consider as appropriate the Bill's proposed removal of
x-rays of a person's body as a prescribed procedure for determining age. The evidence during the inquiry indicated that many persons accused of people smuggling offences have been found to be children as a result of x-ray age assessment procedures, and consequently have been repatriated.[108] It is clear that x-ray age assessments can operate for the benefit of defendants who are children. In the view of the committee, Australian courts are competent to assess the forensic value of evidence placed before them, and should have access to all relevant evidence in determining the age of a defendant, including x-ray age assessments where necessary.

2.68      The committee appreciates the medico-ethical concerns raised regarding the use of x-ray procedures for non-therapeutic purposes. However, in the opinion of the committee, the risks of the low levels of radiation involved are outweighed by the potential benefits to the defendant (where they are assessed to have been a child at the time of the alleged offence) and to the administration of justice.

2.69      Evidence presented to the committee during the inquiry suggests that some persons accused of people smuggling offences have been detained in Australia for long periods before courts have determined they were children at the time of the offence. The committee considers that Australian authorities should continually endeavour to reduce the time taken for age assessment and determination processes. However, the committee does not support the Bill's proposed 30-day time limit for age determinations. The committee agrees with the evidence from AGD, the AFP and the CDPP that the practical difficulties of this proposal would not render it feasible. For example, it is unclear how a defendant who was clearly an adult, but who claimed to be a child after the proposed 30-day time limit, would be treated under proposed new section 3ZQAA of the Bill.

2.70      Similarly, the committee holds concerns regarding the proposal in the Bill that all persons charged with people smuggling who are, or who claim to be, children at the time of the offence should be remanded in a 'youth justice facility'. As the Commonwealth joint submission noted, this proposal could potentially lead to adults charged with people smuggling offences falsely claiming to be children and, consequently, these adults being detained in facilities with children.

2.71      The Bill's proposed 14-day time limit for authorities to bring people smuggling charges received support from some witnesses and submitters during the inquiry. The committee agrees that persons suspected of people smuggling offences should be charged as soon as possible. However, the committee was persuaded by the evidence of the AFP in relation to the time needed for investigative procedures to take place prior to charges being laid. The committee would be concerned if the AFP were pressured to expedite procedures and lay people smuggling charges in order to meet an inappropriately restrictive statutory deadline. Nonetheless, the committee considers that the Australian Government should review the procedural practices and regulatory requirements of the AFP to assess if these processes can be streamlined.

2.72      The Commonwealth joint submission advised that the Australian Government is considering the possibility of amending legislation to expressly provide that the prosecution bears the onus of proof that a person accused of people smuggling was over 18 years of age at the time of the offence.[109] The committee supports this clarification. While some submitters to the inquiry argued that the standard of proof in age determinations should be raised to 'beyond reasonable doubt', in the view of the committee, the current standard of proof of 'on the balance of probabilities' remains appropriate.

2.73      Considerable support was expressed by submitters and witnesses for a multidisciplinary or holistic approach to age assessment for those accused of people smuggling who claim to be children. In particular, the importance of gathering information from the person's place of origin was repeatedly emphasised. This was considered significant due to the lack of reliable documentary evidence of age in many cases and the lack of an accurate scientific procedure for age assessment.

2.74      This evidence gathering process has many practical difficulties, including the requirement for persons to travel to foreign countries and the possibility of additional delays. However, the evidence of Victoria Legal Aid to the committee highlighted how this evidence gathering process from a person's place of origin could assist those accused of people smuggling offences who claim to have been children at the time of the offence. In the view of the committee, the Australian Government should review this area to identify if further assistance should be made available to the legal representatives of those accused of people smuggling offences to undertake this form of evidence gathering in appropriate circumstances. Potentially, this evidence gathering process would give courts additional information upon which to make determinations about age and, if undertaken promptly, may reduce the time accused people smugglers spend in detention.

Recommendation 1

2.75      The committee recommends that the Australian Government review the Australian Federal Police's procedural and legislative requirements in dealing with persons suspected of people smuggling offences, with a view to facilitating the prompt laying of charges where appropriate.

Recommendation 2

2.76      The committee recommends that the Australian Government introduce legislation to expressly provide that, where a person raises the issue of age during criminal proceedings, the prosecution bears the burden of proof to establish that the person was an adult at the time of the relevant offence.

Recommendation 3

2.77      The committee recommends that the Australian Government review options to support the capacity of the legal representatives of persons accused of people smuggling offences who claim to be underage at the time of the offence to gather evidence of age from their place of origin.

Recommendation 4

2.78      The committee recommends that the Senate should not pass the Bill.

Senator Trish Crossin
Chair

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