When imposing a single sentence under s 18A for multiple unconnected offences, the sentencing judge must first assess notional individual sentences (prima facie cumulative for unconnected offences), apply discounts for mitigation to each, arrive at an aggregate, and only then apply the totality principle. Failure to follow this sequence risks double-counting discounts and producing a manifestly inadequate sentence. For historical offences, sentencing tariffs at the time of commission are relevant to the notional individual assessments.
The full text is available to signed-in members, including the 65 later cases that cite this judgment.
14 of the 65 citing cases carry a classified treatment. How each court treated it is available to signed-in members.