Where substantive offences are overt acts in furtherance of a charged conspiracy, they fall within the 'one transaction rule' and should be treated as part of one multi-faceted course of criminal conduct for sentencing purposes, though this does not necessarily require concurrent sentences if the total effective sentence appropriately reflects total criminality. A failure to comply with s 34(2) of the Sentencing Act 1995 (WA) cannot of itself constitute a miscarriage of justice warranting appellate intervention. The word 'between' two dates on an indictment does not include the end dates unless otherwise specified.
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