Section 4K(3) and (4) of the Crimes Act 1914 (Cth) only permits a single penalty for multiple offences against the same provision of a Commonwealth law; offences under different provisions require separate penalties. Where an impecunious offender will inevitably serve imprisonment in default of a fine, the court must have regard to the default period in ensuring the penalty is proportionate to the offending conduct. The appropriate divisor for calculating default periods under WA State legislation was $150 as at March 1999.
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