A finding of 'substantial emotional harm' under s 21A(2)(g) of the Crimes (Sentencing Procedure) Act requires evidence specifically directed to that issue, normally in the form of a victim impact statement, disclosing an emotional response significantly more deleterious than that which any ordinary person would have when subjected to the relevant offence. The ordinary fear experienced by victims of armed robbery does not, without more, establish this aggravating factor. When accumulating a sentence upon an existing sentence, the sentencing judge must apply the principle of totality and consider whether the accumulation constitutes a special circumstance warranting departure from the statutory proportion between head sentence and non-parole period.
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