A non-parole period of 77% of the head sentence may be manifestly excessive where the offender has very good prospects of rehabilitation, profound remorse, no prior convictions, and an early guilty plea, even for a very serious offence of intentionally causing serious injury. The case also illustrates the limits of comparative sentencing analysis: while comparable cases provide some guidance on the sentencing range, reasoning that a sentence is manifestly excessive simply because worse cases attracted similar sentences is insufficient.
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