Fraud offences involving the issuance of fraudulent certificates that undermine the integrity of a government-regulated licensing or training system are serious and warrant actual custody to reflect general deterrence, even where the monetary amounts are modest. Sentencing judges may properly have regard to official corruption cases as comparators while distinguishing them as more serious. A custodial component of four months on head sentences of 20 months to two years for such offending over a 20-month period involving 29 certificates is within the permissible range.
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