For grievous bodily harm involving unprovoked alcohol-fuelled street violence with kicking of a victim on the ground causing life-threatening injuries, where the offender has a prior conviction for similar violence, a sentence of three years imprisonment suspended after 10 months is manifestly inadequate; the Tupou benchmark of 15 months actual custody before release applies as the most lenient end of the range. Where an offender requires structured rehabilitation support, a parole recommendation is preferable to a suspended sentence. Where a sentence is varied under s 669A(1) and the original sentence date preceded s 160B, the repealed s 157 applies with s 213(1) deeming the recommendation date as the parole eligibility date.
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