In double fatality culpable driving cases, some cumulation of sentences will ordinarily be appropriate unless special circumstances call for a merciful outcome, in order to reflect the seriousness of the offence and the need for deterrence. A total effective sentence that treats the second death as effectively without consequence will be manifestly inadequate. However, the head sentence on individual counts of culpable driving based on gross negligence without alcohol may be within range at four years where mitigating factors are present.
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