Where multiple charges of negligently causing serious injury arise from the same conduct (a single driving episode injuring multiple passengers), cumulation must be carefully moderated to ensure the total effective sentence is consistent with the sentencing judge's own characterisation of the offence range and does not contravene the totality principle. A total effective sentence of six years for mid-range NCSI offences arising from a single episode of driving was held to be reasonably arguable as manifestly excessive.
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