Systematic fraud on the Commonwealth social security system involving false identities, extended periods of offending, and a substantial criminal history of fraud offences will ordinarily require a period of actual imprisonment, notwithstanding mitigating factors such as dependent children and post-sentence compliance with probation. The failure of prior non-custodial sentences including probation with psychiatric counselling to deter further offending is a significant factor pointing to the inadequacy of a fully suspended sentence.
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