Where the Crown appeals against the inadequacy of sentence for one offender but not a co-offender, the lenient sentence imposed on the co-offender not the subject of appeal may be taken into account as justifying a further degree of restraint in re-sentencing, following R v Guthrie. The case also illustrates that a sentencing judge's findings of severe personality disorder, extremely guarded prognosis, very poor rehabilitation prospects, and significant re-offending risk do not support markedly lenient sentences — such findings may instead engage considerations of community protection under Veen (No 2).
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