R v C [2007] EWCA Crim 680, [2007] All ER (D) 362 (Mar)
The court gave guidance on the imposition of extended sentences under the Criminal Justice Act 2003, ss 227 and 228.
(i) There is nothing unlawful about the imposition of a concurrent or consecutive sentences.
(ii) The Court of Appeal will not interfere where extended or indeterminate sentences are justified, unless the practical result is manifestly excessive, or for some reason gives rise to real problems of administration.
(iii) However, judges should try to avoid consecutive sentences if that is at all possible and adjust the custodial term or minimum period within concurrent sentences to reflect the overall criminality if that is possible within other sentencing constraints.
(iv) If consecutive sentences are considered appropriate or necessary, if one or more of those sentences is a determinate sentence, the determinate sentences should be imposed first, and the extended sentence or sentences expressed to be consecutive.
(v) In shaping the overall sentence, judges should remember that there is no obligation for the sentences to be expressed in historical
