Where multiple charges of reckless conduct endangering life arise from the same temporally limited conduct (e.g., driving on a footpath in one direction then the other), orders for cumulation must sufficiently acknowledge the overlapping nature of the criminality, and differential cumulation between groups of charges arising from the same aspect of conduct requires explanation. The offence of recklessly exposing an emergency worker to risk by driving (s 317AE Crimes Act 1958) has not yet been considered in sufficient numbers to establish a reliable sentencing profile.
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