When assessing whether a finding of special circumstances has been adequately reflected in the non-parole period, the focus should not be solely on percentage proportions; the actual length of the parole period is equally or more important. Where the sentencing judge deliberately set the non-parole period at a particular level and the resulting parole period is not shown to be insufficient for the identified purposes, the CCA will not intervene. Following Hili v The Queen, there is no 'norm' for the ratio between non-parole and parole periods, even where special circumstances are found.
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