Youth of a juvenile offender is a subjective consideration personal to the offender and cannot be treated as an objective factor reducing the seriousness of the offence. Treating youth as both an objective and subjective factor would involve impermissible double-counting. The greater the objective gravity of the offence, the less scope there is for the ameliorative principles under s 6 of the Children (Criminal Proceedings) Act 1987 to operate. A judicial recommendation to the Parole Board regarding sex offender programme completion has no legal effect absent statutory basis.
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