The case provides guidance on sentencing for failing to stop and failing to report offences under the increased maximum penalties introduced in 2008, where no established sentencing range yet exists. It confirms that where an offender did not cause the collision, the collision occurred in daylight with bystanders available to assist, and no injuries were exacerbated by the failure to stop, the offending is not within the upper range of seriousness. A total effective sentence of 8 years 4 months for drug dealing, failing to stop, failing to report, and attempting to pervert the course of justice was held to infringe the totality principle.
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