A sentence of 16 years (NPP 12 years) for a s 33 offence committed by offenders aged 17-18 was reduced to 13 years (NPP 9 years) on the basis that insufficient weight was given to youth, immaturity, and rehabilitative prospects. The principles in R v GDP and R v Hearne regarding the importance of rehabilitation for youthful offenders apply even in cases of extreme violence, subject to a suitable balance being struck. Where the prosecution relies on lies only as going to credibility and not as consciousness of guilt, a Zoneff direction is appropriate and an Edwards direction is not required.
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