Section 6D of the Sentencing Act 1991 (Vic), which requires the court to regard community protection as the principal purpose of sentencing serious offenders, applies to the fixing of the non-parole period as well as the head sentence. The term 'sentence' in s 6D is not confined to the head sentence. Bugmy v The Queen (1990) 169 CLR 525, which cautioned against undue weight on community protection in fixing minimum terms, was decided before s 6D was enacted and does not govern the application of that provision.
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