When sentencing for multiple offences post-Pearce v The Queen, a judge is not required to set differentiated sentences precisely proportionate to the criminality in each individual offence, and it will more often be necessary to make some sentences cumulative. The totality principle requiring the judge to check the total effective sentence against total criminality was reaffirmed, not superseded, by Pearce. The R v Ellis discount for voluntary disclosure is reduced where it was highly probable guilt would have been discovered independently.
The full text is available to signed-in members, including the 4 later cases that cite this judgment.
1 of the 4 citing cases carry a classified treatment. How each court treated it is available to signed-in members.