Where a single course of dangerous driving endangers multiple victims, cumulation orders reflecting the separate impact on each victim are appropriate even where the criminality of the charges overlaps, provided the principle of totality is observed. The absence of remorse, poor criminal history for driving offences, and substance abuse not reducing moral culpability supported sentences at the upper end of the range for offences under ss 22 and 317AE of the Crimes Act 1958 (Vic).
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