Complete concurrency between discrete offences committed on different days, involving different types of offending and different victims, is not appropriate and may render a total sentence manifestly inadequate. For aggravated robbery involving firearms in the ACT, a starting point of four years was manifestly inadequate where the offence involved an ambush, multiple uses of firearms, and actual violence by a co-offender. The COVID-19 pandemic and its impact on conditions of imprisonment (including suspension of visits) is a relevant factor in the residual discretion on prosecution sentence appeals, though the majority declined to exercise the discretion on the facts of this case.
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