The one-transaction rule does not apply where a stolen motor vehicle is used for the purpose of enabling a robbery and making apprehension more difficult, as the theft adds substantially to the criminality of the enterprise. Section 87 of the Sentencing Act 1995 (WA) does not permit backdating of a sentence for periods during which the offender was in custody serving an earlier sentence following suspension of parole, even though the offender was also on remand for the current offences. A history of repeated breaches of probation and parole provides compelling reasons for refusing parole eligibility, such that refusal is inevitable absent exceptional circumstances.
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