A global sentence of imprisonment under s 18A of the Criminal Law (Sentencing) Act 1988 (SA) cannot include offences that are individually punishable only by fine. Where offences punishable by fine only are charged separately, they cannot be used as aggravating features to elevate another offence to the level of seriousness warranting imprisonment. This applies the Samuels v Young double punishment principle in the context of s 18A global sentencing.
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