The double jeopardy discount that constrains the Court of Appeal on Crown sentence appeals does not apply when an offender appeals his own sentence under s 568(4) of the Crimes Act 1958 (Vic). An offender who appeals a manifestly inadequate sentence risks having it increased without any double jeopardy discount. Practitioners advising co-offenders must consider the practical implications where a Crown appeal against one co-offender's sentence has been dismissed on double jeopardy grounds.
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