Where a sentence for escape from lawful custody is mandatorily accumulated on an existing sentence, the sentencing judge must consider the impact of accumulation on the overall non-parole period ratio and give reasons for any refusal to find special circumstances. A bare statement that the existing non-parole period will 'adequately cater for rehabilitation' is insufficient where the evidence supports special circumstances including harsher custodial conditions from assistance to authorities, threats to safety, and health conditions.
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