Concealment of a murder victim's body may be treated as an aggravating factor in assessing compensation for grief and trauma under s 85B of the Sentencing Act 1991 (Vic). The balancing of compensation needs against an offender's rehabilitation prospects under s 85H(1) is quintessentially a matter for the trial judge, and appellate intervention is warranted only where the judge acted on a wrong principle or arrived at a result not reasonably open. Awards of $120,000 to a father and $60,000 to a step-mother were within range for a murder involving concealment of the body for 17 months.
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