Section 44 of the Crimes (Sentencing Procedure) Act 1999 does not mandate a relationship between the aggregate non-parole period and the aggregate head sentence when sentencing for multiple offences; the section governs the ratio for each individual sentence. The extent of adjustment for special circumstances is a matter of sentencing discretion, and the CCA will only intervene if the non-parole period is manifestly inadequate or excessive. Whether a first custodial sentence alone constitutes special circumstances remains doubtful.
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