Extra-curial punishment as a mitigating factor in sentencing does not extend to deliberately self-inflicted injury sustained in the course of committing the offence (per Grove J and Johnson J). Campbell JA left open whether there might be some circumstances in which deliberately self-inflicted detriment could mitigate, but agreed that on the facts — where the injury was intimately bound up with the criminal conduct and the extent of disability was not well established — there was no error in declining to treat it as mitigating. A highly disturbed emotional state at the time of offending, without psychiatric evidence of a mental disorder or abnormality, does not of itself diminish culpability.
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