Orders under s 19B of the Crimes Act 1914 (Cth) are rare in cases of forging and uttering, and the circumstances in which it is appropriate to invoke s 19B have been described as rare, exceptional and special or singular. 'Extenuating circumstances' under s 19B(1)(b)(iii) require a link between the circumstances relied upon and the commission of the offence; general personal difficulties are insufficient where the offending conduct was deliberate.
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