An aggregate sentence that conflates distinct family violence offences of varying seriousness committed at different times risks manifest inadequacy by failing to recognise the relative seriousness of each offence. Breach of a family violence intervention order is an aggravating feature that must be expressly recognised. Characterising family violence offending as 'situational' because it occurred within a relationship minimises its seriousness. The intended interstate relocation of an offender does not justify declining to fix a non-parole period without considering interstate parole transfer arrangements.
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