Section 61(1) of the Crimes (Sentencing Procedure) Act 1999 does not introduce a code narrower than the common law 'worst case' category; both avenues for a life sentence remain available. Where multiple murders of vulnerable victims are committed in quick succession for the offender's satisfaction, subjective circumstances including a deprived childhood cannot displace the need for life sentences. No power exists under the current legislative scheme to fix a non-parole period for a life sentence imposed under s 19A of the Crimes Act 1900, as Division 1 of Part 4 of the Crimes (Sentencing Procedure) Act 1999 is the sole source of power for setting non-parole periods and it does not apply to life sentences.
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