Riot offences directed at police officers warrant starkly deterrent penalties, and an intensive correction order or suspended sentence will ordinarily be manifestly inadequate for active participants in a serious riot targeting police, even where the offender has no prior criminal history. The fact that a riot was triggered by perceived police misconduct does not significantly mitigate the seriousness of the offending for sentencing purposes. Where an appeal court is satisfied a respondent should clearly have been imprisoned, the fact that the respondent has been at large under an intensive correction order does not preclude the imposition of actual imprisonment on appeal.
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