The reasoning in DPP v Bulfin concerning the particular significance of general deterrence in sentencing white collar offenders continues to apply notwithstanding the expanded availability of community correction orders under the Sentencing Act 1991 (Vic) as amended in September 2014 and the Boulton guideline judgment. A short period of imprisonment combined with a CCO is not relevantly distinguishable from a longer sentence with a wide gap between head sentence and non-parole period for the purposes of the Bulfin analysis. However, a CCO is not categorically excluded for white collar offenders — the Bulfin considerations remain relevant factors in the sentencing exercise.
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