The offence of offering a bribe to police in the course of their duties is a most serious offence striking at the heart of the criminal justice system. Save in the most exceptional circumstances, it requires a significant term of imprisonment imposed cumulatively or at least substantially cumulatively upon the sentence for the primary offence. A wholly concurrent sentence that leaves the offender effectively unpunished for the bribery offence constitutes manifest inadequacy indicative of serious sentencing error. The fact that a bribery attempt did not reach fruition is not a mitigating factor.
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