An order for cumulation may be challenged as manifestly excessive under s 278 of the Criminal Procedure Act 2009 (Vic), even where the individual sentences are within range. Where the offence of attempting to pervert the course of justice arises from the same proceedings as the underlying offences, the close connection between them must be reflected in the cumulation order. The fact that an offender has not previously served actual imprisonment is a relevant factor in assessing totality.
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