A sentencing judge who refers to the standard non-parole period and identifies a hypothetical sentence after trial does not necessarily use the standard non-parole period as an impermissible 'starting point', provided the judge has conducted a detailed analysis of the full range of objective and subjective considerations. The assessment of objective seriousness is quintessentially for the sentencing judge and is reviewable on appeal only on House v The King principles. A sentence may nevertheless be manifestly excessive where the subjective case is strong and not adequately reflected in the final sentence.
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