The case consolidates six propositions governing the relevance of summary disposability to sentencing in the District Court: the sentencing judge is not bound by Local Court limits but may have regard to them; the fact that a matter could have been dealt with summarily is a relevant consideration but not a universal mitigating factor; and failure to mention it does not necessarily establish error. A sentencing judge's characterisation of prior criminal record as an 'aggravating feature' of the offence (rather than as relevant to the appropriate sentence) constitutes error under Veen (No 2) principles, but such error may be immaterial where the remarks on sentence as a whole demonstrate proper regard to the criminal history.
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