For juvenile offenders of extreme youth facing first custody, rehabilitation and not deterrence must be the primary focus of sentencing. A sentencing judge who gives express primacy to deterrence over rehabilitation for such an offender commits appealable error. The vulnerability of a victim whose age is an element of the offence under s 66A cannot be treated as an aggravating factor under s 21A(2) of the Crimes (Sentencing Procedure) Act 1999.
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