Where subjective circumstances have already been given significant weight in reducing the head sentence, care must be taken that they are not given undue significance again in reducing the non-parole period under s 44(2) of the Crimes (Sentencing Procedure) Act 1999, resulting in a disproportionately low non-parole period. The principles requiring resentencing at the lower end of the appropriate range following a successful Crown appeal apply equally to the variation of a non-parole period.
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