The totality approach to sentencing for multiple offences recognised in Griffiths v The Queen was not impliedly overruled by Pearce v The Queen. A sentencing judge may fix a sentence for the most serious offence reflecting overall criminality, but should not do so where it would result in double punishment, collateral parole consequences, or artificial disparity with co-offenders. The strict interpretation of Pearce adopted by the NSW Court of Criminal Appeal in R v Hammoud is not followed in Queensland. Attacks on railway officials performing their duties justify severe punishment, though railway officials are not in the same special sentencing category as police officers.
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