Where a sentencing court makes a finding of non-exculpatory duress, it must undertake an articulated assessment of the impact of that finding on the objective gravity and moral culpability of the offences, having regard to the form and duration of the criminal conduct, the nature of the threats, and the opportunities available to report to authorities. A failure to do so constitutes sentencing error. General deterrence remains a very substantial factor even where non-exculpatory duress is established.
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