In sentencing for multiple counts of Commonwealth fraud, a broad-brush approach grouping offences by category rather than precisely correlating individual sentences to amounts involved will not be set aside on appeal provided the instinctive synthesis is not impugned and the total effective sentence is within range. However, sentencing judges should ordinarily explain the basis for grouping and any apparent disparities between sentences for offences involving markedly different monetary amounts. General deterrence remains the pre-eminent sentencing consideration in social security fraud cases.
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