Three planned and co-ordinated armed robbery offences committed at separate premises on the same night are not part of one criminal enterprise for the purposes of concurrency, even where committed over a short period. Section 44 of the Crimes (Sentencing Procedure) Act 1999 (NSW) does not mandate a relationship between the overall non-parole period and the overall sentence when sentencing for multiple offences. Prior criminal convictions are relevant beyond individual deterrence, contrary to the sentencing judge's finding.
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