Counts of offering to supply a drug of dependence to induce a person to continue in prostitution (s 8(1)(c) Prostitution Control Act 1994) and trafficking in a drug of dependence (s 71(1) Drugs, Poisons and Controlled Substances Act 1981) are not alternative counts — they have different elements, address different evils, and may be supported by different evidence, permitting conviction on both. Partial cumulation of sentences on such paired counts is appropriate where the offences constitute separate and distinct courses of criminal conduct.
The full text is available to signed-in members, including the 4 later cases that cite this judgment.