Where multiple domestic violence offences arise from the same failed relationship and the offender's psychological condition, the totality principle may require all sentences to be served concurrently even though the offences are distinct in time, place and circumstances. The two-stage process for considering suspended imprisonment described in Dinsdale need not be expressly articulated provided the sentencing court has properly considered the relevant matters. Schedule 1, clause 2(5) of the Sentencing Legislation Amendment and Repeal Act 2003 (WA) applies where the statutory penalty (not the summary conviction penalty) has been amended since the new provisions commenced.
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