On a sentence appeal alleging manifest excessiveness, the focus must be on the sentence actually passed rather than the sentencing judge's notional starting point. Judicial Commission statistics showing sentences actually imposed are of little use in challenging a notional starting point, and a sample of 16 offences over 5 years is too small to establish a sentencing pattern. A combined discount of 50 percent for plea of guilty and assistance to authorities represents the upper limit of what is normally appropriate, and the resulting sentence must still reflect the objective seriousness of the offence and not fall below the irreducible minimum.
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