Where co-offenders in a joint criminal enterprise receive manifestly inadequate sentences, the parity principle may operate to prevent the Court of Criminal Appeal from increasing sentences on some offenders while leaving others' sentences undisturbed. The R v Henry guideline for robbery offences requires that the starting point before discount reflect the objective seriousness of the particular offence, not merely the bottom of the guideline range. Home invasion, multiple victims, and significant planning are substantially aggravating factors that must be reflected in the sentence.
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