The normal tariff for conventional armed robbery of a bank in Western Australia is in the range of 6 to 9 years. When applying the totality principle to multiple armed robbery offences committed while on parole, a total effective sentence of 12 years with early parole is not manifestly excessive where the sentencing judge has heavily discounted individual sentences and made appropriate concurrency orders. Under s 22 of the Sentencing Act 1995 (WA), where a sentencing judge does not make new sentences cumulative on an earlier term, the first sentence runs concurrently with any unexpired parole period.
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