Where an offender commits serious offences against multiple victims arising from the same incident, substantial accumulation of sentences is required — an accumulation of only 6 months for a second serious assault on a separate victim is manifestly inadequate. The 'middle range of seriousness' for offences under s 112(2) of the Crimes Act 1900 (NSW) is practically impossible to determine given the breadth of serious indictable offences the section encompasses. Where multiple charges share a common element (such as break and enter), sentences must be structured to avoid double punishment for that element, in accordance with Pearce v The Queen.
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