Section 44 of the Crimes (Sentencing Procedure) Act 1999 applies to individual sentences and does not require a sentencing judge to maintain any particular ratio between the balance of term and the total effective non-parole period across accumulated sentences, provided the judge has adverted to the cumulative effect. A sentencing judge who is aware of the Children (Criminal Proceedings) Act 1987 and implicitly rejects lesser sentencing options does not err by failing expressly to address s 18(1). The question of whether the statutory ratio should be maintained across accumulated sentences remains contested, with Adams J's dissent articulating a stricter approach.
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