Indicative sentences under s 53A of the Crimes (Sentencing Procedure) Act 1999 (NSW) are not themselves amenable to appeal; the focus is on whether the aggregate sentence reflects total criminality. The principles of accumulation and concurrency at general law have no application to aggregate sentences; the principle of totality governs. A sentencing judge's characterisation of offending as 'worst case category' that is inconsistent with individual assessments of objective seriousness may be disregarded on appeal where the individual assessments are not challenged.
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