The principle that rehabilitation of young offenders should generally be given primacy in sentencing does not operate as an absolute proposition; in cases of particularly serious violence, deterrence and denunciation may properly reduce the weight given to youth and rehabilitation. A s 6AAA declaration is not part of the sentence and the declared discount is not examinable for specific error; the question on appeal is whether the sentence actually imposed was excessive. Where a period of detention cannot count as pre-sentence detention under s 18 of the Sentencing Act 1991 because the offender was simultaneously serving another sentence, it should nonetheless be taken into account under the Renzella discretion.
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