Victim impact statements regarding the grief of the deceased's relatives cannot be taken into account as an objective fact in sentencing for manslaughter, following R v Bollen and R v Previtera. However, where such error is established, re-sentencing is not required if the same sentence would be imposed. A sentence at the bottom of the range for manslaughter by provocation is not necessarily manifestly inadequate. The approach in R v Alexander to making express findings about the degree of provocation may be implicitly complied with even where express findings are not made.
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