The orthodox approach to sentencing for multiple offences is to fix appropriate individual sentences and then determine cumulation; the 'moderate and cumulate' approach should only be used in special circumstances. The parity principle and the language of 'understandable sense of grievance' apply only to co-offenders sentenced for the same or related offences; comparison with a low sentence imposed on an unrelated offender for different offences does not give rise to a parity issue. In Commonwealth drug sentencing, quantities should be expressed as a percentage of the commercial quantity to enable meaningful comparisons between cases.
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