Section 6 of the Children (Criminal Proceedings) Act 1987 (NSW) permits a court to structure sentences so as to ensure a youthful offender's non-parole period expires before the offender turns 18, thereby enabling access to juvenile justice rehabilitation programmes. The principle that rehabilitation is the primary focus for youthful offenders does not mean that general deterrence is irrelevant, particularly for serious violent offences such as robbery in company. Partial accumulation of sentences for discrete offences committed by a youthful offender is appropriate and not erroneous where the offences are separate in time and involve different victims.
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