When imposing multiple limiting terms under s 23 of the Mental Health (Forensic Provisions) Act 1990, the sentencing judge must ensure that the overall structure of the terms — including any backdating — does not inadvertently produce complete accumulation where only partial accumulation is intended. A hiatus period between sets of limiting terms that results in complete accumulation may render the overall terms unusually harsh and severe. The standard non-parole period may remain relevant as a legislative guidepost in the limiting term exercise, notwithstanding s 54(c), though this question was not decided.
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