The two-stage approach to natural life sentences under s 61(1) is confirmed: first, whether the objective gravity brings the offence within the worst category; second, whether subjective circumstances require a lesser sentence. An offender's treatment of the deceased's body after death is relevant to objective seriousness. The sentencing judge need not be satisfied of risk of re-offending beyond reasonable doubt. A life sentence is not reserved only for cases where there is no chance of rehabilitation; it may be appropriate where culpability is so extreme that the community interest in retribution and punishment can only be met by life imprisonment. The absence of any one or more of the s 61(1) indicia (retribution, punishment, community protection, deterrence) does not preclude a life sentence but may make it more difficult to justify.
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