The case confirms that the degree of accumulation of sentences for multiple offences is a discretionary matter that will not be disturbed on appeal absent House v The King error. Temporal proximity of offences does not of itself require greater concurrence. The most useful approach to structuring multiple sentences is to identify the appropriate overall sentence reflecting total criminality and adjust accumulation to yield that result.
The full text is available to signed-in members, including the 2 later cases that cite this judgment.
1 of the 2 citing cases carry a classified treatment. How each court treated it is available to signed-in members.