A sentencing judge dealing with a child offender is not required to make specific formal reference to s 6 of the Children (Criminal Proceedings) Act to avoid appellable error; practical compliance is sufficient. The proposition that the Henry armed robbery guideline judgment does not apply to child offenders was doubted but not definitively resolved. Concessions normally extended to child offenders may be qualified where the offence involves particularly serious objective criminality, especially where the offender is approaching 18 years of age.
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