When imposing a cumulative sentence under s 156A of the Penalties and Sentences Act 1992 (Qld), the sentencing court must give specific and separate consideration to s 9(2)(l) and the sentences already imposed that have not been served. A failure to do so, combined with shortcomings in submissions, may constitute exceptional circumstances warranting appellate intervention even where the sentence was adopted from defence counsel's own submission. A parole eligibility date set at the one-third mark of a cumulative sentence may be appropriate to avoid a crushing aggregate sentence.
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