The 60-66% non-parole period practice for Commonwealth offences does not operate as a ceiling; higher ratios can stand, particularly where dual pressures of accumulation and totality require adjustment. The historical basis for the 60-66% practice may be questionable following the repeal of remission provisions. Where Commonwealth and State offences are sentenced together, the approach in Cahyadi of treating the State regime as 'unfair' may not always be appropriate, particularly where State offences are not merely incidental. The question of whether 'in company' aggravation under s 21A(2)(e) extends to fraud offences committed with an accomplice (where there is no coercive effect on the victim) was left open.
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