Section 21A(2)(l) of the Crimes (Sentencing Procedure) Act 1999 (vulnerability of victim) is directed to the weakness of a particular class of victim and not to the threat posed by a particular class of offender; the fact that persons generally would be vulnerable to a proficient fraudster does not engage the provision. Section 21A(2)(m) (multiple victims or series of criminal acts) is concerned with a single offence containing multiple criminal acts as part of a single course of conduct, and is not to be applied where the multiplicity of victims and criminal acts is already addressed by the multiple offences charged and the totality principle.
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