An offender's breach of conditional liberty for a serious offence at the time of committing a further serious offence is a significant aggravating factor that can counterbalance the mitigating effect of youth, such that a juvenile offender may properly receive a sentence comparable to adult co-offenders without giving rise to a justifiable sense of grievance on parity grounds. A proportionally shorter non-parole period relative to co-offenders may demonstrate adequate consideration of youth.
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