A victim surcharge order imposed against the appellant was unlawful as his offences had been committed prior to October 1, 2012, when an order could only be imposed if the defendant was sentenced to a fine, which was not the case with the appellant.
2012 CHANGE OF NAME CRIMINAL PROCEDURE FINES FRAUD NOTIFICATION REQUIREMENTS OFFENCES COMMITTED PRIOR TO OCTOBER 1 SENTENCING SEXUAL OFFENCES ACT 2003 s.91 UNLAWFUL ORDER UNLAWFUL SENTENCES VICTIMS SURCHARGE
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