A bare reference in sentencing remarks to a matter being a 'factor of aggravation' under s 21A does not necessarily mean the sentencing judge increased the sentence on that basis; the Court will examine the sentencing remarks as a whole to determine whether the factor was in fact taken into account in aggravation. There is no bright line rule requiring a lesser sentence for a secondary participant compared to the principal offender; the relative culpability of co-offenders must be assessed according to individual circumstances.
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