Section 15 of the Sentencing Act 1991 (Vic), which directs the order in which sentences of imprisonment are to be served, applies to sentences imposed for contempt of court. Where an originating motion alleges two discrete contempts, separate penalties must be imposed for each. A dissociative state caused by underlying psychiatric illness (reactive depression, anxiety disorder) points to insane automatism, not non-insane automatism. The question whether ss 11 and 14 of the Sentencing Act 1991 (non-parole periods) apply to contempt sentences was left open.
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