Where an offender has a mild intellectual disability (IQ 68, bottom 2% of population) and a profoundly deprived Aboriginal background, general deterrence has little role to play and personal deterrence is of questionable relevance. However, wholly concurrent sentences for distinct offences against different victims require compelling justification, and the absence of any accumulation for a separate robbery offence constitutes sentencing error even where the offences form part of a temporal continuum. On Crown appeal, the residual discretion may be exercised to limit the degree of intervention to a moderate increase.
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