A person had pleaded guilty to manslaughter of a child and was sentenced to a three and a half years imprisonment. The state appealed, arguing that the sentence was an insufficient punishment for a crime of such magnitude. The Court of Appeal of Samoa cited the CRC regarding the right not to be subjected to cruel treatment or punishment. It held that “[a]ll Samoan Courts should have regard to this Convention in cases within its scope.” The Court then quashed the original sentence and replaced it with a five-year sentence.

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