Gambling addiction, even where pathological and listed in DSM-V, will not generally be a mitigating factor at sentence for fraud offences, particularly where general deterrence is important and the offences are planned and perpetrated over an extended period. The disorder will not generally reduce moral culpability because the offender retains a degree of choice as to how they finance their addiction, and the addiction merely provides a motive or explanation rather than being directly connected to the commission of the crime. In sentencing for rolled up counts, the criminality involved is greater than a charge involving only one episode of criminal conduct, and prior good character is not a matter of great significance in breach of trust cases as generally only persons of good character are placed in positions enabling such offences.
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