There is no fixed principle that sentences for supplying prohibited drugs and dealing in proceeds of crime must be wholly concurrent; each case must be evaluated on its own facts having regard to totality and whether the sentence for one offence can comprehend the criminality of the other. Where an aggregate sentence is imposed, the appellate court cannot analyse concurrence and accumulation in the same way as traditional sentencing structures, and the ultimate question is whether the aggregate sentence reflects overall criminality.
The full text is available to signed-in members, including the 2 later cases that cite this judgment.
1 of the 2 citing cases carry a classified treatment. How each court treated it is available to signed-in members.