Where a sentencing judge imposes fixed terms as the equivalent of minimum terms, the notional starting point (before discount for plea and adjustment for special circumstances) must not exceed the maximum penalty for the offence. The question whether uncharged conduct forming part of a course of conduct may be taken into account to increase the objective seriousness of representative charges (beyond merely denying leniency) was not definitively resolved, with the majority of the Court declining to adopt Basten JA's analysis pending full argument in an appropriate case.
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