There is no 'one transaction rule' in NSW requiring concurrent sentences for offences arising from the same criminal episode. Where offences involve different conduct, at least some cumulation is required to reflect total criminality. Offences of perverting the course of justice under s 319 of the Crimes Act, like bribing a police officer, are interferences with the criminal justice system that ordinarily require cumulative or substantially cumulative sentences for general deterrence purposes.
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