In one of our recent articles, our Lawyer’s discussed the “Four Angels Law” in the aftermath of the Oatlands Crash which took the lives of Anthony, Angelina and Sienna Abdallah and their cousin, Veronique Sakr. Since 1 February 2020, Samuel Davidson, the man responsible for the deaths, plead guilty to the following charges in October 2020:

  1. Four counts of manslaughter pursuant to section 18 of the Crimes Act 1900 (NSW);
  2. Two counts of grievous bodily harm by misconduct in charge of a motor vehicle pursuant to section 117 of the Road Transport Act 2013 (NSW); and
  3. One count of aggravated dangerous driving occasioning grievous bodily harm while under the influence of drugs pursuant to section 52A(iii) of the Crimes Act 1900 (NSW)

On Friday 9 April 2021 at Parramatta District Court, Judge Bennett sentenced Davidson to a maximum of 28 years behind bars with a non-parole period of 21 years. Having already served time on remand, he will be eligible for release in January 2041.


It is important to remember that the offence of manslaughter carries a maximum sentence of 25 years. Davidson’s sentence, although by no means lenient, was given a maximum of 28 years due to the particularly aggravating factors present in his offending. Pursuant to section 21A of the Crimes (Sentencing Procedure) Act 1999 (NSW), a criminal offence may be “aggravated” and as a result, be objectively more serious due to a variety of factual circumstances. In terms of the criminal offence committed by Samuel Davidson, the following aggravating factors would have had a significant impact on the total sentence:

  1. the offence was committed in the presence of a child under 18 years of age,
  2. the injury, emotional harm, loss or damage caused by the offence was substantial,
  3. the offence was committed without regard for public safety,
  4. the offence involved a grave risk of death to another person or persons,
  5. the victim was vulnerable, for example, because the victim was very young or very old or had a disability, or because of the victim’s occupation (such as a taxi driver, bus driver or other public transport worker, bank teller or service station attendant),
  6. the offence involved multiple victims or a series of criminal acts,

In addition to the abovementioned factors, the sentencing Judge is required to take into account any other objective or subjective factor that could affect the relative seriousness of the offence. During sentencing, Judge Bennett disclosed graphic details of the injuries the four deceased children sustained to the head, limbs and internal organs. In addition, Judge Bennett also referred to the physical and emotional trauma the three surviving children endured stating Mr Davidson “stole their innocence”.

Although the Court referred to many aggravating factors, an accused person is entitled to have any mitigating factors taken into account when determining punishment. During the sentencing hearing, Mr Davidson’s apology letter was read out in court where he promised “not to touch alcohol or drugs again”. In addition, his plea of guilty is another factor which must be taken into account as a mitigating factor.


The dangers associated with driving whilst intoxicated by drugs and/or alcohol cannot be ignored. Currently, the Road Transport Act 2013 (NSW) establishes the following penalties for drink driving for a first offence:

  • Low range PCA (0.05 – 0.079) $2,200 fine;
  • Middle range PCA (0.08 – 0.149) $2,200 fine or 9 months imprisonment (or both); and
  • High range PCA (0.15 and above) $3,300 fine or 18 months imprisonment (or both).

Since the ‘Four Angels Law’ has been tabled by Parliament earlier this year, the proposed amendment to the Road Transport Act 2013 (NSW) seeks to include a separate offence for ‘compound alcohol and drug driving’. The new law, which will be referred to as a section 111A, offers a maximum penalty of two years imprisonment and/or a $11,000.00 fine.


Whilst National Criminal Lawyers® acknowledges that the ‘Four Angels Law’ is aimed at reducing death on our roads, we understand that sometimes people make mistakes. Our lawyers at National Criminal Lawyers are some of the most experienced in Traffic Law. If you or someone you know has been caught in a traffic offence, contact us to get the best defenders of your rights.

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