When accumulating sentences across multiple indictments, sentencing judges must consider the overall effect on the proportion of the non-parole period to the head sentence. A non-parole period of 90% of the total sentence is disproportionate and warrants appellate intervention, particularly where the sentencing judge has not addressed the issue. The accumulation of sentences can itself constitute 'special circumstances' under s 44(2) of the Crimes (Sentencing Procedure) Act 1999.
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