When assessing whether a juvenile offence is 'particularly heinous' under s 121(3)(b)(ii) of the Juvenile Justice Act 1992 (Qld), only the circumstances of the killing itself are relevant — the offender's subsequent conduct in dealing with the body is excluded from that assessment. The worst category test from Ibbs and Veen (No 2) applies to juvenile sentencing under the Act, requiring features of very great heinousness and the absence of objective mitigating factors. The risk of danger to the community may be taken into account in determining the weight to be given to subjective mitigating factors.
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