The customarily recognised range of 4 to 6 years' imprisonment for armed robbery in Western Australia (post-2003 amendments) does not define the boundaries of the sentencing discretion but serves only as a yardstick. A total effective sentence of 10 years 6 months for nine offences committed over approximately two hours on the same day, where the most serious individual offences attracted sentences of 4 years and 4 years 6 months, infringed the first limb of the totality principle; 8 years 6 months was the appropriate total.
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