Commonwealth social security fraud involving failure to declare a relationship or income to Centrelink, without the use of false identities or false documents, is to be treated as a less serious category of offending under s 134.2(1) Criminal Code Act 1995 (Cth), warranting a shorter period of actual custody before release on recognizance than cases involving systematic fraud through false identities. Mitigating features including rehabilitation, employment, reparation payments, and care responsibilities must be weighed against deterrence in determining the period to be served.
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