In sentencing for wilful murder, the primary focus in assessing gravity must be on aggravating factors that are present, not on factors that are absent; while absent factors may be material, an offender falls to be sentenced for what he or she did. There is no general principle that 'failed relationship' or domestic murders are inherently more or less serious than other homicides. The tension between Williams (no factor has primacy) and [name withheld] (gravity has primacy) is resolved: in an individual case where seriousness is ranked high, gravity may override other factors, but this is not a legislative prescription that seriousness is always the first consideration.
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