The parity ground in sentence appeals should be understood as asking whether it was reasonably open to the sentencing judge to differentiate (or fail to differentiate) between co-offenders as he or she did, rather than focusing on the offender's subjective sense of grievance. A sentencing judge is under no obligation to notify parties or invite further submissions if proposing to sentence above the upper end of the Crown range. A Crown submission on range is no different from any other submission and the judge is free to reject it.
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