A rolled-up count is fundamentally different from a representative count: it is a collection of offences bundled into a single count by agreement with the defence for the purpose of a guilty plea, and the sentencing judge is entitled to impose a sentence reflecting all offences encompassed by the count. The compression of multiple counts into a rolled-up count operates to the advantage of the accused by reducing the theoretical maximum sentence. A sentencing judge may refer to uncharged criminal damage caused during burglaries as context for sentencing without falling into error.
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