Under the Juvenile Justice Act 1992 (Qld), a court may lawfully impose a probation order on one offence concurrently with a detention order with an immediate release order on a separate offence, because s 121C only restricts the combination of detention and probation for a single offence. The line of authority under the Penalties and Sentences Act 1992 (Evans, Lihou, Hughes, M) prohibiting concurrent probation and imprisonment does not apply to juvenile sentencing under the separate statutory scheme. Non-custodial sentences for serious offences by juveniles with no criminal history and good rehabilitation prospects may not be manifestly inadequate given the Act's emphasis on rehabilitation and detention as a last resort.
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