There is no general principle requiring full-time custodial imprisonment for single-offence employee dishonesty involving breach of trust and a substantial but not enormous sum, although such a principle does exist for defalcating professionals or others whose crimes are of considerable extent and wide effect. The key aggravating features distinguishing cases requiring full-time custody are: professional status, systematic dishonesty, planning and sophistication, multiplicity of offences, and wide public effect. The Court's residual discretion to dismiss a Crown appeal may be exercised where the sentence has been substantially served, there has been delay in bringing the appeal, and any re-sentencing would have a disproportionately onerous effect relative to the limited increase in punishment.
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