A psychological explanation for an offender's tendency to resort to violence in domestic relationships cannot substantially reduce the importance of that tendency as a significant aggravating factor for sentencing purposes. There is no 'usual' standard or normal non-parole period expressed as a proportion of the head sentence; the question is whether it was reasonably open to the sentencing judge to fix the non-parole period actually fixed. Reliance upon sentencing statistics for manslaughter by unlawful and dangerous act carries more than considerable limitations given the variance in conduct constituting the offence.
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