A sentencing judge may properly treat a contravention of an ADVO as relevant to the objective seriousness of a detain offence while also imposing a separate consecutive sentence for the contravene ADVO offence, provided the judge delineates between the two aspects: the ADVO contravention as context for the detain offence, and the discrete criminality of breaching a court order intended to protect a vulnerable person. The brevity of a detention is of limited assistance to an offender where the detention did not end at the captor's choosing but was terminated by third-party intervention.
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