In sentencing for robbery in company, the objective circumstances of the offender's specific role must be carefully assessed. Where the offender did not personally threaten the victim, did not directly apply corporal violence during the robbery, and did not personally take the victim's property, a sentence at the higher end of the range may be manifestly excessive even where the offender has a significant prior record and committed the offence while on parole. The commission of an offence while on parole properly operates as an aggravating factor under s 21A(2)(j) of the Crimes (Sentencing Procedure) Act 1999, and the consequences of breaching parole may operate in three ways: as an aggravating feature of the new offence, as revocation of parole, and as the commencement date of the new sentence being set at the expiration of the parole period.
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