The parity principle may be infringed by a lack of disparity (identical sentences) where differences in culpability and circumstances reasonably justify a shorter sentence for one offender. However, an offender's motivation, the role of a co-offender in initiating the scheme, and the application of stolen funds do not necessarily reduce relative culpability where countervailing factors such as a significantly larger amount stolen and lack of insight into offending weigh against the offender. The Court left open whether the parity principle applies between offenders whose offending overlaps but who are not strictly co-offenders.
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