The established principle that robbery offences should be regarded 'in virtually all circumstances' as offences of utmost seriousness carrying a custodial sentence must include the qualifying word 'virtually'; omitting it overstates the position. Armed robbery is generally more serious than robbery simpliciter, and the objective seriousness of each offence must be assessed on its own facts. Bag snatching offences remain particularly serious as breaches of the peace. A non-parole period may be reduced where the offender is young and has made genuine rehabilitation efforts, particularly in overcoming drug addiction.
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