In Victoria, the commission of an offence whilst on bail constitutes an aggravating factor that may lead to an increase in sentence beyond what would otherwise have been imposed, not merely a factor reducing mitigating circumstances. The narrower view expressed in R v Gray [1977] VR 225 is not to be followed on this point. The approach is consistent with the New South Wales line of authority and with the legislative policy reflected in s 16(3C) of the Sentencing Act 1991.
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