When sentencing for offences committed in the 1980s, the non-parole period should be set at between one third and one half of the head sentence, reflecting the sentencing practice that existed at that time, and the existence of that practice constitutes special circumstances within s 44(2) of the Crimes (Sentencing Procedure) Act. Where cumulative sentences are imposed for multiple offences, special circumstances should be found to maintain a reasonable ratio between total non-parole periods and total head sentences.
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