The degree of accumulation or concurrency between sentences for drug offences remains a matter within the broad discretion of the sentencing judge. Where two drug offences involve largely separate criminality — one being a joint enterprise to obtain a commercial quantity and the other being independent retail supply — full accumulation with a reduced non-parole period on the second offence may properly give effect to the principle of totality. An appellant who does not identify error of principle, extraneous considerations, or mistake of fact faces a difficult task in demonstrating House v The King error from the structure of sentences alone.
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