Sep 24, 2026

9 min

R v Odisho [2026] NSWDC 337

R v Odisho [2026] NSWDC 337 concerns sentencing for unlawfully selling firearms three times or more within 12 months and dealing with $12,500 in proceeds of crime. Odisho negotiated three pistol sales through encrypted communications; two were completed, while the third did not proceed. The key issue was whether alleged threats linked to a substantial debt established non-exculpatory duress. Beckett DCJ rejected that claim as vague and insufficiently proved, but accepted that refugee-related childhood disadvantage, difficult acculturation and PTSD reduced moral culpability and, to some extent, general deterrence. After a 25% guilty-plea discount, the Court imposed an aggregate sentence of five years and two months, with a three-year and five-month non-parole period.

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