The non-parole period for strict security life imprisonment is the minimum time justice requires the offender to serve, determined by reference to all relevant sentencing factors including the circumstances of the offence, aggravating and mitigating factors, and the offender's antecedents. The prospect of rehabilitation is relevant but should not be the primary focus; giving undue weight to rehabilitation is likely to result in the lowest available minimum term. The approach in Lauritsen, which applied by analogy the repealed s 89(2) factors with emphasis on rehabilitation, is deficient in material respects.
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