Charges of grievous bodily harm with intent to disfigure (s 317) are not mere particulars of a charge of torture (s 320A) even where the offences arise from a single episode of offending, because the offences are distinguished by their respective intention elements. Cumulative sentences may properly be imposed for these distinct offences, provided the total sentence is proportionate to the total criminality. The torture offence does not require proof of injury, while s 317 requires both intent to disfigure and actual grievous bodily harm.
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