A finding of special circumstances in relation to individual sentences does not mandate that the overall non-parole period must reflect a departure from the statutory ratio; a sentencing judge may deliberately structure accumulated sentences so that the overall ratio approximates the statutory proportion. The parity principle does not arise for consideration in relation to overall sentences where co-offenders were not participating in a common criminal enterprise and were sentenced on substantially different factual bases. A disparity in the finding of special circumstances between co-offenders does not give rise to a justifiable sense of grievance where all relevant facts and circumstances are not equal.
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