When imposing a single sentence under s 18A of the Criminal Law (Sentencing) Act 1988 (SA), a sentencing judge is not required as a matter of law to identify notional individual sentences for each offence, though it is desirable to do so. The standard penalty range for armed robbery on commercial premises remains six to eight years imprisonment. Multiple armed robberies committed at separate premises against separate victims within a short period are properly treated as requiring at least partially cumulative sentences, even where they form part of a single planned course of conduct. White J's view that an adequate explanation of the derivation of the single sentence is required, while not the majority position on error, provides guidance on best practice.
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