Substantial non-sexual violence is not required before a s.61I offence moves above the middle of the range of objective seriousness; victim vulnerability and premeditation may suffice. A sentencing judge is entitled to make a neutral finding on rehabilitation prospects (neither favourable nor unfavourable) where the offender shows no remorse, without being required to make a positive finding based on youth and prior good character alone. Offences by taxi drivers against vulnerable passengers attract a substantial element of general deterrence reflecting the position of trust.
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