The four principles governing appellate review of non-parole periods are restated: the non-parole period is the minimum term justice requires; there is no 'usual' non-parole period; the question is whether it was reasonably open to the judge to fix the period fixed; and exceptionally the Court may find the period manifestly failed to give effect to the judge's stated intention. Sentencing judges should avoid phrases like 'shorter-than-usual' or 'longer-than-usual' non-parole period and instead state the period is 'shorter than it would otherwise have been'.
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