The incremental approach to upward adjustment of current sentencing practices, while no longer good law after DPP v Dalgliesh and Carter v The Queen, could only have benefited an offender sentenced before Dalgliesh by constraining the sentencing judge to incremental rather than full adjustment. Harrison's statement about maintaining appropriate sentencing relativities survives Dalgliesh: increases in sentences for more serious offences will inevitably impact sentences for less serious offences. A summary offence of driving with a prescribed concentration of drugs does not constitute double punishment when charged alongside indictable reckless conduct charges that include drug-affected driving as a particular, because the summary offence is committed upon commencement of driving and does not require proof that drugs affected driving.
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