A plea of guilty to murder will not necessarily avoid the imposition of a life sentence; the plea may instead be reflected in the fixing of the non-parole period. The sentence of life imprisonment remains appropriate for a wide variety of deliberate criminal killings, and the question of the head sentence should not be approached on the basis of considering whether there could be murders of worse gravity. Where a sentencing judge misstates the psychiatric evidence as to an offender's intellectual capacity, this may constitute an error of language rather than a demonstrable error in the exercise of the sentencing discretion, provided the error does not materially affect the assessment of culpability.
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