Where dangerous driving causes more than one death, wholly concurrent sentences will rarely be appropriate because the criminality will not usually be sufficiently comprehended by a sentence appropriate for a single offence. The number of persons actually placed in danger by the offender's driving (as distinct from the general public at risk) is relevant to moral culpability. The Whyte guideline of not less than 3 years for a typical case assumes a guilty plea with limited utilitarian value; absence of a guilty plea removes that discount. True contrition requires acceptance of guilt, and persistent denial of criminal responsibility affects both denunciation and rehabilitation prospects.
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