A court should be slow to promulgate a guideline judgment where the offence encompasses a wide range of offending behaviour, there is no history of Crown appeals suggesting systematic sentencing inadequacy, and significant sentencing reforms have recently been enacted but not yet tested. The absence of Crown appeals is a strong indicator that sentencing inadequacy has not been regarded as systematic. The sentencing principles requiring courts to support police authority and give full weight to general deterrence in assault police cases were reaffirmed.
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