For non-premeditated domestic murders, sentences in excess of 20 years are reserved for exceptional cases involving premeditation or particular brutality, though aggravating features such as a history of domestic violence, criminal record, and being on bail can justify a sentence above 20 years. The precise scope of Hawkins v The Queen (1994) 179 CLR 500 regarding the relevance of mental disorder evidence to intent for murder in NSW remains unresolved.
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