An escalating scale of sentences imposed based on the chronological order of offences rather than their individual seriousness constitutes sentencing error where the offences are of similar objective seriousness. The mere fact of accumulation of sentences does not constitute or require a finding of special circumstances, though the effect of accumulation on the proportion between non-parole period and head sentence must be monitored. When a jury discovers prejudicial non-evidentiary material during deliberations, the adequacy of the trial judge's directions is assessed by whether the court can be satisfied the irregularity did not affect the verdicts.
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