When sentencing for multiple offences in South Australia using s 18A, the court must first assess individual sentences for each offence (including specific deductions for plea of guilty), aggregate those sentences, and only then apply the totality principle. The two-stage approach identifying a specific discount for plea of guilty remains the correct approach in South Australia notwithstanding High Court criticism of that approach. A combined reduction of approximately 55% from the aggregate starting point (one-third for plea of guilty plus a further substantial totality reduction) may result in a manifestly inadequate sentence for serious armed robbery and sexual offending.
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