The Boulton guideline judgment, which promotes CCOs as an alternative to imprisonment for serious offences, does not apply to the sentencing of federal offenders in Victoria. A CCO cannot be combined with a term of imprisonment for a single federal offence because Part 1B Division 4 of the Crimes Act 1914 (Cth) makes exhaustive provision for non-parole periods and recognizance release orders. However, a CCO may be imposed for one federal offence while imprisonment is imposed for another federal offence on the same indictment. Even in the state sphere, Boulton does not create a presumption that a CCO is suitable for any particular offence.
The full text is available to signed-in members, including the 27 later cases that cite this judgment.
6 of the 27 citing cases carry a classified treatment. How each court treated it is available to signed-in members.