Where a young offender commits multiple serious sexual offences, a reduction from the total of individual sentences to an effective sentence of less than 25% of that total through concurrency may constitute a misapplication of the totality principle. Even for a 16-year-old offender with an extremely deprived background, the number and seriousness of offences — particularly repeated sexual violence — may require that community protection and deterrence prevail over rehabilitation as the dominant sentencing consideration under s 125 of the Young Offenders Act 1994 (WA).
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