Section 57 of the Crimes (Sentencing Procedure) Act 1999 does not apply to dictate the commencement date of a sentence for escape where the escape occurred during the balance of a parole period rather than during a non-parole period. In such cases, the commencement date is governed by the sentencing judge's discretion under s 47. A sentence for escape that is backdated so as to effectively overlap with the existing parole period, without resulting in a meaningful additional period of custody, may be manifestly inadequate.
The full text is available to signed-in members, including the 84 later cases that cite this judgment.
32 of the 84 citing cases carry a classified treatment. How each court treated it is available to signed-in members.