Sentencing judges dealing with multiple offences should consider moderating individual sentences and directing partial cumulation rather than imposing a heavy sentence on one count with full concurrency on others. Failure to adopt this approach makes a sentence unnecessarily vulnerable to appellate intervention. The combined effect of R v Newman and Turnbull and Pearce v R supports this approach. Manifest disparity remains a discrete ground of appeal that cannot be subsumed within a ground of manifest excess.
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