Where unrelated offences are charged on separate presentments, a measure of cumulation is ordinarily appropriate, and a sentencing judge's decision to make all sentences concurrent at the Crown's invitation may result in an inappropriate sentence structure, though the Court of Appeal will be reluctant to interfere solely on that basis if the total effective sentence is within range. A single judge should not refuse leave to appeal against sentence solely because the arguable ground would probably not succeed at the full hearing.
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