Members of the same organised crime syndicate who are charged with different offences arising from different factual circumstances are not strictly co-offenders for the purposes of the parity principle in Lowe v The Queen. However, fairness may require comparative assessment of their sentences where the sentencing exercise was conducted with reference to related offenders. Differences in role within the syndicate hierarchy, period of offending, and whether the offender was on conditional liberty are legitimate bases for significant differences in head sentences.
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