The case confirms that a sentencing judge may characterise a juvenile offender's conduct as qualitatively different from mere juvenile behaviour where the offender escalates from immature conduct to deliberate violent confrontation, and may accordingly give significant weight to punishment and deterrence alongside rehabilitation. The physical appearance and employment status of a juvenile offender are relevant but ancillary considerations. A sentence of 6 years with a 4 year non-parole period for a 16-year-old who committed manslaughter by a single punch was held to be within range.
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