A sentence of 3 years and 9 months' imprisonment (after a 20% plea discount) for a very serious aggravated assault causing bodily harm in a domestic violence context, committed while on bail, is within the appropriate sentencing range under s 317(1)(a) of the Criminal Code (WA). Full cumulation of sentences for separate domestic violence offences committed 21 months apart, resulting in a total effective sentence of 7 years and 6 months, does not infringe the first limb of the totality principle where the later offence represents a significant escalation in violence.
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