Where a sentencing judge makes a finding of special circumstances, the statutory ratio of non-parole period to total sentence must be varied sufficiently to give practical effect to that finding; a variation resulting in a non-parole period of 74% of the total sentence does not adequately reflect such a finding. The parity principle as discussed in Lowe v Regina does not strictly apply where co-offenders in an organised crime syndicate were not sentenced for the same transactions, but their sentences may serve as useful comparative sentencing decisions.
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