DISSENTING REPORT BY SENATOR HANSON-YOUNG


DISSENTING REPORT BY SENATOR HANSON-YOUNG

Introduction

1.1        The Crimes Amendment (Fairness for Minors) Bill 2011 that was the subject of this inquiry seeks to establish fair, timely and human rights consistent procedures under Commonwealth criminal law regarding the prosecution of non-citizens, alleged to be 'people smugglers' (boat crew working on asylum seeker vessels), who say they are a child.

1.2        The reforms proposed by the Bill were supported by the following submitters:

Royal Australian and New Zealand College of Radiologists

Australian Human Rights Commission[1]

Human Rights Law Centre

Migrant and Refugee Rights Project, University of New South Wales[2]

Australian Lawyers for Human Rights[3]

Victoria Legal Aid[4]

Australian Lawyers' Alliance[5]

ChilOut[6]

Queensland Commission for Children and Young People and Child Guardian

Western Australian Commissioner for Children and Young People

Tasmanian Commissioner for Children

South Australian Guardian for Children and Young People

Victorian Child Safety Commissioner

New South Wales Commission for Children and Young People

Australian Capital Territory Children and Young People Commissioner

Northern Territory Children's Commissioner

Immigration Advice and Rights Centre

Liberty Victoria

Youth Advocacy Centre

Background

1.3        As noted in the majority report, this Bill was introduced in the context of increased numbers of people smuggling prosecutions, and amidst a growing concern, amongst legal professionals, media, citizens and advocacy groups across Australia, about unclear and unjust procedures in people smuggling prosecutions.

1.4        The Commonwealth agencies advised the Committee that as a general rule, and purely on the basis of policy, a person who is suspected of people smuggling but believed to be a child is returned by Australian authorities to the child's country of origin without charge.

1.5        Evidence was given to the Committee that around one in four people alleged to be people smugglers is returned to country of origin (often Indonesia) on account of being assessed as minors. There is no suggestion on the figures that children are increasingly being used as boat crew; according to the Attorney-General's Department the proportion of minors has been relatively consistent since 2008.[7]

1.6        The Legal Aid Commissions in both Victoria and New South Wales provided case studies outlining the way in which youthful, illiterate young people from the Indonesian archipelago find themselves facing criminal charges in Australia.  Victoria Legal Aid, a submitter to the inquiry, has acted in a number of people smuggling matters and submitted that the facts of the cases usually resemble the below:

The crew are told that they will be transporting cargo and the asylum seekers are only brought onboard once at sea.

The crew are only transferred onto the boat shortly before Australian waters and the organisers then depart on a second boat.

The crew are only told that that the people they are transporting are to be taken to Australia once they are on the High Seas and cannot return.

The crew are told that once they transport people to Christmas Island, Ashmore Reef or Cartier Island that they will be paid and allowed to return home.[8]

1.7        Victoria Legal Aid's statistics on the rate of findings of childhood in age determinations show that one in ten persons held and charged in Victoria for people smuggling turned out to be a child:

Of the 63 prosecutions of crew initiated in Victoria to date, eight have been discontinued because the accused were found to be children. This equates to 12.7%, or more than one in ten, accused having been found to be minors.[9]

1.8        The issue of the treatment of children has highlighted a range of procedural problems in the prosecution of alleged boat crew, or 'people smugglers’, which have the effect of exposing foreign national children to unacceptable delays and time in custody which no Australian child, either in Australia or overseas, would hope to face.

1.9        The Australian Greens were pleased to be informed by the Commonwealth agencies appearing in this inquiry that since December 2011 the process has been clarified so that, from that date, no person who has been assessed as a child will be nonetheless referred to the Australian Federal Police (AFP) and detained for months unnecessarily. The Commonwealth agencies could not be drawn on why this change in policy was brought about, but we see it as affirmation of the growing momentum of public and professional concern about the way these cases are proceeding. However, such important matters as the long term detention of foreign children are too important to be left to variable and opaque policy positions, and as such, the Committee’s recommendations that policy reviews continue do not go far enough.

Time limits on charges and age determination

1.10      One of the key aims of the bill was to establish reasonable timeframes for the laying of charges and the conduct of age determination proceedings before a court.  Almost all submitters, including Victoria Legal aid, noted that one that of the problems with long pre-charge detention in immigration detention means 'there is no court with oversight of their condition or if the processes are being followed'.[10]

1.11      The inquiry unearthed statistics regarding the detention of Indonesians that can only be described as shocking, for both children and adults charged with people smuggling. Victoria Legal Aid submitted that their clients who were ultimately found to be minors spent an average of 6.9 months in immigration detention being charged, and spent an average 9.3 months in immigration detention and prison before having charges withdrawn.[11]

1.12      Some very startling evidence on pre-charge and pre-trial detention statistics of Indonesian nationals was submitted to the inquiry. Senator Hanson-Young raised those statistics in the public hearing:

I have some figures in relation to the length of time that minors were held in some form of detention or on remand prior to a court ruling that they were minors and their cases could not go ahead...The first I have is one person being held for 734 days before the court found that they were a child. The next one was held for 516 days before the court found that they were a child. The next ones were held for 616 days, 490 days, 510 days. Those are all cases where the court found that these Indonesian nationals were children.

...I point out that the last one I read out, 510 days, was a case that ended in Victoria. The other cases were from WA. Then there are young people who are detained, held, imprisoned as adults until the CDPP decide that they do not have enough evidence and they do not want cases to fall over in the courts, so they drop the cases. I will go through some of those as well. One person was held for 735 days; for the other one it was 717 days; for another, 656 days; for another, 510 days before the court decided that this person was indeed a minor; and, for another, 511. They are shocking lengths of time for a child to be held in prison, in detention, before our Commonwealth department of prosecution decides that in fact they are children and they should not be there.[12]

1.13      The Joint Submission for the Commonwealth agencies, and the AFP evidence given to Senator Hanson-Young in Additional Estimates on 13 February 2012, clarified that the AFP aims for a pre-charge detention period of 90 days. This time frame was quite rightly described by Mr Saul Holt from Victoria Legal Aid in the hearing as 'still an extraordinary delay...something which in the ordinary course many would find intolerable'.[13] 

1.14      NSW Legal Aid provided the Committee with useful comparative material for Australians who are taken into custody for suspected criminal offending:

In NSW police can only hold people they arrest on suspicion of committing and offence for four hours for investigation, and any further detention requires a warrant be issued through a court. Under the Commonwealth legislation the situation is similar.

In Victoria, the Crimes Act 1958 requires that police release on bail or unconditionally release or bring a person in custody for an offence before a bail justice or Magistrates' Court within a reasonable time of being taken into custody. The Charter of Human Rights and Responsibilities Act 2006 provides in part that a person in Victoria must not be subjected to arbitrary arrest or detention and that a person charged with a criminal offence is entitled to minimum guarantees including a guarantee to be tried without unreasonable delay.

Even the so-called anti-terror legislation places times limits on detention and requires court           involvement in supervising extended detention for investigation.[14]

1.15      Similarly, Victoria Legal Aid commented:

If one reflects on the public outcry about the detention of Dr Mohammad Haneef for a number of days without charge in 2007 on suspicion of terrorism offences, it is difficult to reconcile how the Australian Parliament can tolerate the systematic arbitrary detention of accused people smugglers for, in the Victorian experience, an average of over seven months.[15]

1.16      These unacceptably drawn out pre-charge and pre-trial periods of detention were said by many submitters to be in breach our international obligations. The Migrant and Refugee Rights Project submitted as follows:

In particular, inappropriate age determination procedures result in (1) incarceration of children in adult correctional facilities, and (2) exposure of children to the general human rights violations that affect all individuals charged with smuggling offences, including lengthy and arbitrary pre-charge detention, lengthy pre-trial detention, and the application of mandatory minimum sentences. Each of these legislative and procedural failures undermines compliance with Australia's human rights obligations under international law, including under the International Covenant on Civil and Political Rights ('ICCPR'), and, in the case of children, the Convention on the Rights of the Child ('CRC').[16]

1.17      The Commonwealth agencies argued that the provisions for timelines in the Bill would be too onerous to meet on a practical level. They submitted evidence that the current average time between intercept and charge is 104 days.[17] 

1.18      Assistant Commissioner Jabbour told the Committee that it would not be feasible to charge suspected people smugglers within the 14 day timeline outlined by the Bill because the AFP would need time to interview the passengers, departmental and customs officials and obtain statements with specially trained interpreters.

1.19      The Australian Greens have more faith in the AFP's abilities to organise initial investigations than to accept this evidence. As pointed out by legal submitters, most of the witnesses and officials are easily accessible in secure immigration detention on Christmas Island. There is no need to go into the wider community to find them to make a statement. A brief of evidence sufficient for the laying of charges does not necessarily need to be as full and complete as the brief that will ultimately be relied upon by the prosecution at trial. Further, the complexity and breadth of evidence required is likely to be less considering the very clear circumstances in which the accused is intercepted at sea.

1.20      The Australian Greens depart from the majority report which states that it would place 'undue pressure' on the AFP to expedite procedures. We do not consider it justified to renege on reasonable and human rights consistent time-lines relating to the charging of vulnerable foreign nation children on the basis of convenience to Australian agencies. It is not undue pressure on the AFP to require that the AFP lays charges in a reasonable and expedited manner that does not breach our obligations against arbitrary and unjust detention of children.

1.21      Victoria Legal Aid urged the Committee to recommend the timelines in the Bill because it is a feasible time line:

Two weeks is sufficient time for an accused to be interviewed by the AFP on Christmas Island before being conveyed to another State or Territory for a charge to be laid and prosecution commenced. The prosecuting authorities would then be given adequate time to compile a brief of evidence. In Victoria, this is typically three months.[18]

1.22      We also note that while the Committee heard evidence that all young Indonesian people are immediately given an opportunity to have a phone call with a lawyer when initially taken into custody, this contradicts a large volume of anecdotal evidence from amongst the legal profession and referred to by the Migrant and Refugee Rights Project.[19]

1.23      We also note the evidence given by lawyers that the Indonesian families of their young clients had no idea where their child was for months and years, and many believed them to have died. It is imperative that all effort are made to notify the parents of the whereabouts and welfare of any person accused of people smuggling who says they are a child.

1.24      The Australian Greens support the position of the legal professionals acting in these matters that 'we should not be aspiring to three months delay; we should be aspiring to no or very little delay...The generally accepted view in international law is there should be no pre-charge detention in the absences of exceptional circumstances'.[20]

Wrist x-rays

1.25      The Bill removes the taking and use of discredited wrist (or other skeletal)
x-rays in the age determination processes. The wrist examination process is one of the key delaying factors in the pre-trial process, as it only occurs in a certain location (usually Darwin). The use of bone x-rays is a highly imprecise science that has been rules out by paediatric medical experts, international sports medicine bodies and international bodies.[21] 

1.26      The Australian Society of Forensic Odontology gave this account of the Gruelich and Pyle method:

Hand/Wrist X-ray examination was designed as a tool to assess general skeletal development and overall growth. The reference sample used was a selection of 1000 middle-class American children who were born in the 1930s-1940s, aged from birth to nineteen years of age... It is this atlas that is used in Australia for age estimations.

At no time was this atlas designed to determine chronological age; it was designed as a tool for health workers to better assess a child's skeletal development and overall growth. Clearly, the major drawback when using this technique is that images included in the atlas were obtained some 60 years ago from individuals who grew up on the other side of the world, under environmental conditions totally different to the detainees being assessed.

Biological variation in human development means that any age assessment based on GPRA analysis of growth markers will inevitably contain a degree of error.[22]

1.27      The Royal Australasian College of Physicians put in a submission that was unequivocal about the use of wrist x-rays:

The RACP supports the Bill's proposal that wrist x-rays should not be used to determine age as this method is not reliable or validated for this purpose. The Gruelich and Pyle method (GP method) evaluates the bone age of children by x-raying the left hand wrist.

There is room to investigate alternative methods of age assessment to the methods currently used in Australia. The RACP suggests investigating comprehensive assessments which may include psychological, cognitive, developmental and cultural factors.

In reviewing and developing more comprehensive assessment processes, a multidisciplinary approach is needed. The RACP recommends government work with a range of professional disciplines, such as paediatricians, social workers, psychologists and related professions, to explore and develop comprehensive and balanced assessment processes.[23] 

1.28      This view was backed up by the peak body in the area of radiology, the Royal Australian and New Zealand College of Radiologists:

We understand that there is a push from the Australian government for a scientific/medical method for age determination in the accused refugee population who claim to be juveniles.

However, we object to the current practice of relying on wrist X‐rays or the proposal to use dental X‐rays as a means of determining age due to the lack of evidence that supports its use in this way. Whilst there is no single medical way to accurately determine an individual's age, the government should consider developing a process where age is assessed in a number of ways; this is often referred to as 'holistic' age assessment. This approach incorporates narrative accounts, physical assessment of puberty and growth, and cognitive, behavioural and emotional assessments.

1.29      This peak body for radiologists ended their submission with a very clear recommendation regarding wrist and dental x-rays: 'Bone age assessment should not be used for this purpose in Australia'.[24]

1.30      The Committee also heard from Professor Tim Cole, a Professor of Medical Statistics at MRC Centre of Epidemiology for Child Health, UCL Institute of Child Health, England, who has appeared throughout 2011 in 11 separate age assessment hearings in Victoria, 9 of which ultimately saw charges against the young person withdrawn by the CDPP.

1.31      Professor Tim Cole submitted as follows:

...Bone age is informative only in the minority of cases where the individual says they are much younger than 18, say 14 or 15. In other cases bone age is not informative...[T]hese arguments against the use of bone age apply equally to the use of dental age assessment, based on the appearance of third molars (wisdom teeth).[25]

1.32      We note that in a Senate Budget Estimates hearing in 2011 the Department of Immigration and Citizenship conceded that there is a 4-5 year margin of error in relation to wrist x-rays.[26]

1.33      Professor Michael Ditchfield, Chair of the Paediatric Imaging Reference Group of the Royal Australian and New Zealand College of Radiologists deemed the use of bone x-rays to be unworthy of being included in an age assessment, even with other evidence, on the basis of the margin of error that means 'one in five times it will be wrong'.[27]

1.34      The Human Rights Law Centre supports the abolishment of bone x-rays on the basis of its margin of error:

The HRLC reiterates the principle that any scientific procedure used in the age determination process should be afforded a margin of error and unreliable or discredited age assessment techniques should not be used in evidence.[28]

1.35      Professor Tim Cole referred to a case he appeared in during 2011, in which the prosecution had proceeded with charges even though the likelihood that the defendant was under 18 was 61%. In doing so, the AFP and CDPP had relied on the erroneous expert opinion a single doctor who is based in Perth, who is a gastrointestinal radiologist rather than a skeletal radiologist or paediatric specialist. The joint Commonwealth agencies also confirmed that the same doctor is the expert referred to in their submission at page 20 as the basis for their policy view.[29]

1.36      The Australian Greens believe that relying on the expert opinion of a single radiologist who is not actually an expert in the relevant field of medicine is a highly disturbing practice and should immediately be reviewed by the CDPP.

1.37      Professor Ditchfield referred to the radiation caused to a child through x-ray, which is a low dose but is nonetheless risky.[30] His expert opinion in explaining why the United Kingdom has ruled out bone x-rays as an unlawful practices was this: 'it is very hard to justify performing something that is not of a benefit to a person – where they are actually disadvantaged by performing it'.[31] 

1.38      Professor Ditchfield confirmed that the government had apparently chosen to disregard the concerns raised in a joint letter from peak radiology bodies in Australian and New Zealand that was submitted to the Minister for Immigration and the Attorney-General in August 2011, which raised concerns about bone x-rays and offered to provide expert consultation on the issue.[32]

1.39      The issue of parental consent should also be considered. Under Australian medical law parental consent is relevant to medical procedures relating to children. We query the ethical and legal appropriateness of 'offering' a young person dental and wrist x-rays that may impact on radiation absorbed into their bodies, not to mention have an impact on the legal case against them. As currently stands, there is no, or very little, attempt made by Australian authorities to seek out the parents of a young person prior to returning the child to Indonesia and prior to conducting medical procedures while in detention. The concern about parental consent was raised by the Australian Society for Forensic Odontology:

In any investigation specifically focused on an age assessment, the client must be informed fully of the reasons and 'informed consent' must be obtained before any investigation is undertaken.  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.[33]

1.40      There was some concern amongst submitters that abolishing the bone x-rays altogether would mean that some children would miss out on being returned to Indonesia at an earlier stage than trial stage. Regarding this, the Commonwealth agencies submitted that 37 children have previously been returned solely on the evidence of wrist x-rays. However, as the Committee heard repeatedly from Commonwealth agencies in this inquiry and also in the most recent Additional Estimates in February 2012, it is now the case that x-rays are not relied on as sole evidence by any Commonwealth agency. 

1.41      Mr Thornton told the Committee: 'we have attempted to assist the courts by giving them some indication of what the probabilities are, and at the end of the day, as it has been said, wrist x-rays are not a perfect system: they are just one indicator'.[34] Yet the Commonwealth also said that x-ray scans are 'key evidence' in existing cases:

...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 minor or adult.[35]

1.42      The difference in evidentiary approaches between cases before and after December 2011 would appear to be highly unjust and indicative of the lack of clarity and fairness in this area of public prosecutions broadly.

1.43      Given the change in approach to evidence it is less likely that children in the position of those 37 would necessarily miss out on being returned. It would be an inconsistent position to point to the risks and uncertainties of bone x-rays but accept those scans in a suite of evidence. If information is so uncertain as to be practically irrelevant on an evidentiary basis, as is the case put before the Committee by the medical experts from Australia and elsewhere, then it should be abolished entirely.

1.44      Broadly, all medical and radiology experts, human rights advocates and legal specialists (other than the Commonwealth agencies) supported the use of a holistic age determination process. The Migrant and Refugee Rights Project commented that both the UNHCR and the CRC require states to take numerous sources of evidence into account when determining age. This could include 'comprehensive assessments which may include psychological, cognitive, developmental and cultural factors'.[36]

1.45      The Australian Greens strongly support abolishing the use of bone x-rays due to the risks and uncertainty expressed by medical experts, in favour of a complete, holistic and expedient age determination process starting with the initial interview with the Department of Immigration.

Assumption of age and accommodation while trial pending

1.46      This Bill confirms that people who claim to be minors will be treated as such unless it is proven through age determination process that they are adult. This includes mandating that no person who is possibly a child will be incarcerated in an Australian adult prison or remand centre. This highly regretful situation has indeed occurred in a number of cases where a young person charged as boat crew was placed into an adult prison upon being charged, and where they remained for some months.

1.47      While we endorse the Commonwealth's assurance that bail will ordinarily not be opposed in relation to accused who claim to be children, it is imperative that the accommodation of children out of adult prisons be clearly enshrined in legislation.

1.48      We note the query about the terminology used by the Bill to indicate a place of detention specifically for children, and will consider amendments that clarify what this means across states and territories where criminal law terminologies differ. The Commonwealth expressed some concerns about technicalities of expression in the Bill.

1.49      Nonetheless the clear intentions of the Bill in this regard was thoroughly  understand and supported by many submitters, who asserted that the Act must be clarified to require children to be detained in child-orientated sections of immigration detention or on bail in the community.

1.50      We also note the comments provided by the Youth Advocacy Centre and ChilOut, who both pointed out the singular situation in Queensland where 17-year-olds charged with Commonwealth offences are tried by the Queensland criminal law system as adults.  While the amendment suggested by the goes somewhat outside the ambit of this Bill and inquiry, we recognise the concerns raised and will consider amendments in this regard.

Onus in proving age

1.51      The Bill reiterates the onus that should be borne by Australian prosecuting agencies in assembling a thorough brief of evidence to displace the presumption that the person is a minor.

1.52      Legal representatives including Victoria Legal Aid told the Committee that in a number of cases, they had been able to obtain a range of evidence from the communities in the Indonesian archipelago in a matter of 3-4 days. This process should occur as soon as possible, in order to save the high costs of prosecuting children for people smuggling, both ethical and financial. It should not be difficult for an Australian government authority to undertake the same investigations. Many submitters supported this in relation to age determination:

It is also essential that the Government thoroughly investigates for any evidence which may be available from the accused person's homeland. This should be done early in the process rather than waiting for an external source, such as a prosecutor or defence counsel, to gather the information. It is also essential that the benefit of the doubt is given when the assessment of a person's age is inconclusive rather than risking the detention of juveniles in adult prisons.[37]

Conclusion

1.53      The Australian Greens disagree with the majority report's conclusion that the change of policy and practice since December 2011 is enough to 'ensure that those who are underage will be promptly returned to their country of origin'. This conclusion is not supported by the volume of evidence put before the Committee. The question of early referrals will assist some minors but has no bearing on the extended and delayed processes that occur further down the prosecution track.

1.54      The Australian Greens also prefer the evidence of medical experts to the view of Commonwealth authorities in regards to wrist and dental x-rays.

1.55      The Australian Greens do not agree that the timelines suggested by the Bill are not feasible, on the basis that legal advocates and medical experts have confirmed timelines of far less than 30 days are possible and proven so in numerous case studies.

Recommendation 1

1.56      The Bill be amended to require facilitation of timely access to legal advice, and that regulations require that children are afforded communication with their family.

Recommendation 2

1.57      Item 3 of Schedule 1 of the Bill be amended so that proposed new subsection 3ZQAA(3) of the Crimes Act 1914 provides that the 30 day limit on bringing an application to a magistrate to determine a person's age applies from whichever is first of:

(a)        the date the person is taken into immigration detention; or

(b)        the date on which the person first asserts that he or she was a minor at the time of the alleged offence.

Recommendation 3

1.58      That the Bill be passed by the Senate.

Senator Sarah Hanson-Young
Australian Greens

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