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No Body, No Parole

Written by Shobanah Brind

Content Warning: Includes discussions of Homicide. Mental Health resources are listed below.


In October of 2022, following the trial of Chris Dawson, which will be discussed in further detail below, the New South Wales government introduced new “no body, no parole” laws, with the goal of retrieving further and more precise information regarding the location of a victim’s body.

Usually, when an offender is sentenced, the court automatically imposes a non-parole period, where an offender is required to spend a certain amount of time in custody. After the non-parole period expires, offenders then become eligible to apply for parole.

Under new legislation, particularly in cases of homicide where parole authorities are unsatisfied with the level of cooperation from offenders in identifying the location of their victims remains, they are to be denied the possibility of parole.

The legislation:

The ‘No body, No parole’ (NSW) can be found in:

Crimes (Administration of Sentences) Act 1999, No 93.

Section 135A: “Parole order must not be made where an offender has not cooperated in locating victim’s body or remains.”

So, what is parole anyway?

Parole is a conditional release from prison, whereby offenders are allowed to serve the remainder of their sentence within the community, under supervision and with certain restrictions. The offender will need to address their criminal behaviour, in order for them to be safely reintroduced to society. An example of this may be completing courses to help prevent reoffending, through rehabilitation programs, violence prevention programs and sex offender programs. A court will decide if an offender is eligible for parole, but parole authorities will ultimately decide if an offender will be released into the community of if they continue to pose a threat to the community.

Why was the ‘no body, no parole’ bill introduced?

Former Minister for Counter Terrorism, Minister for Corrections and Minister for Veterans’ Affairs, David Elliot stated that by introducing a ‘no body, no parole’ bill for the state parole authority to consider would:

· Act as an incentive for offenders to give up location of victims remains,

· Help hold offenders accountable for their criminal behaviour, with a focus on what they have done, to help make amends for their crime,

· Ascertain whether an offender has made progress towards rehabilitation, or if they still present a risk to the community

NSW Premier, Dominic Perrottet also mentioned that the bill ensures that the needs of victims’ friends and families are met, putting them at the centre of the bill, by allowing for an opportunity for closure over losing a loved one. “Families deserve the dignity of saying their final goodbyes and we must do all we can to demand offenders give up their secrets and bring some closure to families and friends of victims” – Mr Perrottet, 13th October, 2022.

Commonly referred to as ‘Lyn’s law’, the bill was passed following the nationally known case of Chris Dawson who, after two coronial inquests, was found guilty on 30th August 2022 of murdering his wife Lynnette Dawson, despite her body never being found. The alleged murder took place on 8th of January 1982, after wife and mother of 2 young girls, Lynette Dawson went missing from their Northern Beaches home. Justice Harrison who served as a judge at the trial, completely rejected the idea that Lynette would have abandoned her family. The prosecution’s case was largely built on circumstantial evidence, but Justice Harrison believed that there was a compelling body of evidence to show that it was satisfied beyond a reasonable doubt that Lynnette Dawson died at the hands of Chris Dawson.

Image of Lynette Dawson.

Lynette last spoke to her mother on 8th of January 1982, and had planned to meet with her mother and family the following day, but never arrived. Mr Dawson did not report his wife missing until 6 weeks had passed. Evidence against Mr Dawson included his infatuation with a student, known as JC, with who he had a secret affair with, and married a year after Lynette’s disappearance. (It should be noted that JC was a minor when Mr Dawson showed romantic interest towards her, and therefore any ‘relationship’ they may have shared was indeed not a relationship, but rather is indicative of grooming from Mr Dawson). Justice Harrison believed that Mr Dawson, after JC had travelled to see family and friends, would have become so distressed fearing JC would leave him, that he resolved to killing his wife. Justice Harrison believed that Mr Dawson had fabricated a multitude of lies, including claims that he wanted to continue his relationship with Lynette, suggestions Lynette was still alive, and that Lynette willingly left on her own accord, and did so to “deflect all or any attention away” from his involvement with her disappearance and death. Chris Dawson received a 24-year sentence for the murder of Lynnette Dawson. The sentence carries a non-parole period of 18 years, but under the recent “Lyn’s law”, won’t be eligible for early release until he has disclosed the location of Lynette Dawson’s remains.

Do the ‘no body, no parole’ laws really work?

The ‘no body, no parole’ laws are now in operation across most Australian states and territories, despite the low number of recorded ‘no body’ homicides. Research on 10 ‘No body, no parole’ applicants following the introduction of the law which was passed in Queensland during 2017, found that 6 out of 10 applicants met the satisfactory cooperation standards, meaning that they may had been eligible for parole when the time comes, however, no cases resulted in the victim’s remains being located. It was argued through their research, that there is little evidence, that laws such as these, have been effective in identifying the missing remains of victims. They argue that there is the potential of the law being used for political gain, and possibility of exploitation of the victims’ rights movement, by offering the victim’s loved one’s false hope.

However, one case which is notably used as evidence for the ‘no body, no parole’ laws and their effectiveness is the Leeann Lapham case. Leeann was last seen on the 19th of April, 2010. Graeme Evans who has since been charged with for Leeann’s murder, initially stated that on the day she went missing, the couple had fought and Leeann left the couple’s Motel room and never returned. The case went cold but was reopened in 2016. After police felt they had enough evidence to convict Evans of Lapham’s death, he was charged in February of 2017. Evans pleaded guilty to a downgraded charge of manslaughter and interfering with a corpse. Police say that Evans had been convinced to locate Ms Lapham’s remains, following the ‘no body, no parole’ legislation passed in Queensland in August of 2017. After being told of the whereabouts of Lapham’s remains, police found her body within 20 minutes. Evan’s was sentenced to 9 years in jail, and at the time was eligible to apply for parole on February 8th, 2021. Because of this, Leeann had been brought back to her family.

The innocent person’s dilemma

But what about cases of wrongfully convicted individuals?

Wrongful convictions are a very real issue, not just in Australia, but within criminal justice systems all over the world. Research in the US has shown that the rate of wrongful convictions is likely to be somewhere between 2% and 10%, though these numbers may be much higher. The main causes of wrongful convictions are largely due to eyewitness misidentification, false / coerced confessions, police, and prosecutorial misconduct, flawed forensic evidence and perjured testimony. If an individual is being tried for a murder that they didn’t commit, the ‘No body, no parole’ laws further complicate their case. Innocent people are then faced with a ‘dilemma’. Innocent people who maintain their innocence and do not give up the location of a body (due to having no knowledge of the location of the body), then face a sentence without the possibility of parole. Innocent people who then appear to be attempting to cooperate with police by giving a location (whether they find the body or not) can then be viewed as accepting the responsibility of the crime, which may affect the possibility of having their conviction overturned. These innocent people then may spend years behind bars, away from their life, for a crime they simply didn’t commit.

So, is the ‘No body, No parole’ law something to be happy about?

It’s difficult to tell. Unfortunately, we won’t know just how effective these laws may be until there are more “no body” murders, whereby likely offenders/suspects are encouraged to disclose the location of their victims. By being offered the opportunity to make amends, and hold themselves accountable, offenders having the chance to be released on parole can reduce the stress of overcrowding in prisons – which is a massive issue in itself. However, even if an offender does not lead police to the right location of a body, they can still be viewed as cooperating, and may be offered parole. It seems difficult to be able to determine exactly what might pass as satisfactory cooperation, and what may not. Though these laws were likely passed with victims and their families in mind, it is important to be aware that they pose a very real threat to individuals who may be wrongfully convicted.


Lifeline - Call or Text 13 11 14.

BeyondBlue – Call 1300 22 4636.

Community Restorative Centre – Service available to family and friends of people in NSW Prisons – 02 9288 8700 (Monday to Friday)


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