The Court of Criminal Appeal exercised its inherent power to correct an accidental slip in Order 4 of its earlier judgment in Allen v R [2020] NSWCCA 173, which had omitted reference to the Second Indictment. The variation ensured the aggregate resentence of 18 months' imprisonment applied to counts 2 and 4–25 of the First Indictment and counts 1 and 2 of the Second Indictment, consistent with the court's original intention. The court relied on R v Green and Quinn [2011] NSWCCA 71 as authority for the implied or inherent power to correct such clerical errors of its own motion.
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