A head sentence of 12 years for aggravated breaking and entering under s 112(2) of the Crimes Act 1900 (maximum 20 years, standard non-parole period 5 years) was manifestly excessive where the offence was at the upper end of the mid-range of objective seriousness. Where a sentencing judge finds special circumstances justifying departure from the statutory ratio, the non-parole period must reflect that finding. Motivation is a matter going to objective seriousness and must be considered as part of that assessment, not separately.
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