Differences in criminal records between co-offenders can justify what would otherwise be apparent disparity in sentences, particularly where an offender's repeated drug offending warrants a more severe sentence for retribution, deterrence and protection of society. The parity principle does not require identical sentences where co-offenders have materially different criminal histories. Positioning offending within a notional range is not required for Commonwealth sentencing under s 16A of the Crimes Act 1914 (Cth).
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