When sentencing for offences that form part of a course of conduct for which a prior sentence has already been served, the correct approach is to sentence as at the current date with regard to events since the offending, including the prior sentence, rather than constructing a notional sentence based on a hypothetical earlier sentencing date. The prior sentence is a relevant circumstance but does not call for a separate mathematical reduction from an appropriate sentence. Where offences are sentenced under s 18A as one sentence, separate consideration must be given to each offence and the separateness of the offending may call for significant accumulation of notional sentences.
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