Where s 18(2)(d) of the Sentencing Act 1991 (Vic) prevents a declaration of pre-sentence detention for custody already accounted for by an earlier court, the Renzella principle may be applied to give effect to totality by reducing cumulation between indictments. The case also illustrates the importance of making express orders for concurrency under s 6E when sentencing serious sexual offenders, given the default cumulation requirement.
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