Possession of multiple firearms by a prohibited person in the context of motorcycle gang activity, drug trafficking, and inter-gang violence falls within the second Berichon category warranting substantial custodial sentences significantly beyond 18 months. The practice of fixing sentences just below two years to enable combination sentences with CCOs is inconsistent with correct sentencing principle. The CCO provisions in the Sentencing Act 1991 are producing artificial results and legislative reform is urged.
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