Sentences for domestic violence offending involving breach of intervention orders and bail conditions will be upheld even at the high end of the permissible range where the offender has a lengthy criminal history and prior breaches, notwithstanding the absence of physical violence. The use of s 18A to impose a single sentence without identifying notional individual sentences carries a risk of opacity and potential double punishment. Intoxication in the context of domestic violence offending is an aggravating rather than mitigating factor.
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