A sentencing judge may convert the value of stolen funds to current dollar values using a reliable source such as the Reserve Bank to assist in understanding the gravity of historical offending, provided the judge does not purport to sentence as if the offence occurred at the date of sentence. The approach of cumulating approximately one third of individual sentences on a base count across multiple fraud counts is not inherently arbitrary where the judge has first imposed appropriate individual sentences and then sought to achieve an appropriate total effective sentence in accordance with the totality principle.
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