A sentence for an offence committed in custody that is entirely concurrent with a pre-existing sentence for unrelated offences will ordinarily be manifestly inadequate, as it fails to reflect the separate criminality and undermines general deterrence for prison violence. Full accumulation may be required even where the offender was on remand rather than a convicted inmate, consistent with the policy underlying s 56(2) of the Crimes (Sentencing Procedure) Act 1999 (NSW).
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