A challenge to the degree of accumulation or concurrency of sentences requires identification of House v The King error; a submission that the degree of concurrency was inadequate, without more, is insufficient. Sentencing statistics showing a sentence falls in the highest 5% of sentences for an offence type do not, of themselves, support a finding of manifest excess, particularly where the offence provision covers a wide range of offending. Comparison with a small number of other cases provides limited assistance in establishing manifest excess.
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