A finding of 'special circumstances' under s 44 of the Crimes (Sentencing Procedure) Act 1999 does not necessarily require a significant disturbance of the statutory ratio between non-parole period and head sentence. Post-sentencing medical evidence is only admissible where subsequent events completely undermine the basis on which the sentence was passed; natural deterioration of pre-existing conditions already taken into account by the sentencing judge is insufficient.
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