The determination of the extent of accumulation and concurrency of sentences is a matter of judicial discretion, and an appellant must demonstrate a House v The King error — a submission that the extent of accumulation was 'too great' without identifying a specific error is insufficient. Where an offender has multiple prior convictions for the same type of offence and commits a further offence while on bail, substantial accumulation is justified. The Bugmy v The Queen principles regarding disadvantaged background have limited application where the offender's childhood did not involve abuse, abandonment, or exposure to alcohol and drugs in the home.
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