A total effective sentence of 8 years' imprisonment for fraud offending involving $1.46 million obtained from 10 victims over four years through an elaborate advance fee fraud scheme does not infringe the first limb of the totality principle. The case confirms that the combination of a large amount defrauded, extended duration, elaborate sophistication, multiple unsophisticated victims, and devastating victim impact justifies substantial accumulation of individual sentences. There is no established sentencing range for fraud offences due to the diversity of circumstances in which they are committed.
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