As in the Maumasi case the previous year, the Court of Appeal of Samoa quashed a sentence (this time the sentence of a person who was convicted of engaging in sexual intercourse with a minor) and replaced it with a longer sentence (the nine months sentence was replaced with a three-year sentence). In so doing, the Court cited the CRC again, and quoted the Court’s previous holding in Maumasi, that “[a]ll Samoan Courts should have regard to this Convention in cases within its scope.”

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