Where an offence carries a standard non-parole period, the sentencing court must set a non-parole period for each count and must assess objective seriousness with precision, not merely as 'at least mid-range'. The commission of further offences while on bail is not a relevant consideration in determining whether special circumstances exist for the purposes of s 44 of the Crimes (Sentencing Procedure) Act 1999 (NSW). The Pearce methodology requires individual sentences to be fixed before the overall sentence is assessed for totality and proportionality.
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