R v Green [1986] 2 Qd R 406 should no longer be viewed as imposing a definite upper sentencing limit of approximately six years for 'domestic' manslaughter. Manslaughter is an offence in which circumstances vary so greatly that it is difficult and perhaps undesirable to generalise in advance about appropriate sentences. The van den Bemd direction using a double negative, while undesirable, is not a ground for setting aside a conviction if the direction was comprehensible to an ordinary juror.
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