Sentences of 10 years' imprisonment (NPP 7.5 years) for detain for advantage causing actual bodily harm and 5 years' concurrent for detain for advantage were upheld for a repeat domestic violence offender who committed offences while on bail and subject to an ADVO, confirming that such sentences are within range for objectively serious domestic violence offences. Sentencing statistics and comparable cases are of limited utility for s 86 offences given the wide variety of circumstances in which they are committed. Post-sentence conduct breaching a domestic violence order is admissible on resentencing to assess prospects of rehabilitation.
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