A sentencing judge is not required to expressly identify each Verdins principle by number, provided the substance of the relevant considerations is addressed in the sentencing remarks. However, sentencing judges must not artificially structure cumulation orders to produce a total effective sentence below two years so as to avoid the mandatory non-parole period requirement in s 11(1) of the Sentencing Act 1991. The Court of Appeal identified a systemic problem with s 44 of the Sentencing Act leading to a pattern of 23-month sentences combined with CCOs and called for urgent legislative reform.
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