Sentences of 1 year's imprisonment for failing to report a fatal traffic incident (maximum 10 years) and 2 years' imprisonment for failing to ensure assistance to victims of a fatal traffic incident (maximum 20 years) were manifestly inadequate where the offender abandoned three dying victims, walked home, showered, went to bed, and lied to police, and were increased to 2 years and 4 years respectively. The minimum licence disqualification periods were also manifestly inadequate in such circumstances. Mitchell JA's separate reasons suggest the WA Court of Appeal should discontinue expressing manifest inadequacy/excess conclusions by reference to whether a sentence falls outside the 'available range', favouring instead the formulation that error must be inferred from the result.
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