Solicitors who commit offences involving breach of trust must be sentenced with regard to their special position of trust, not as persons of 'neutral background'. Prior good character is not available as a mitigating factor where the offences are part of a continuing course of criminal conduct designed to conceal earlier criminal activity. The case confirms that the principles in R v Hawkins (1989) 45 A Crim R 430 remain authoritative and that any suggestion in R v Poppert to the contrary should not be followed.
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