The Henry guideline for armed robbery does not expressly deal with offenders whose liability is founded on joint criminal enterprise rather than direct participation. The doctrine of joint criminal enterprise permits considerable flexibility in sentencing according to the role of particular participants, and a sentencing judge may impose markedly more lenient sentences on a secondary participant even for objectively very serious robbery offences. Wholly concurrent sentences for multiple robbery charges committed in the same criminal episode may be appropriate where the offender's involvement was limited.
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