Where two principal co-offenders are found to have different levels of culpability, the difference in their sentences must still bear a proportionate relationship to the difference in culpability and subjective circumstances. A three-year difference in head sentences was held to exceed the permissible range where the difference in culpability, while real, was not of that magnitude. The fact that a co-offender's sentence is lenient but not inadequate does not preclude a finding of disproportionality.
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