A sentencing judge's reference to a spent juvenile conviction under s 189 of the Young Offenders Act 1994 (WA) will not constitute a material error warranting appellate intervention where the appellant's adult criminal history independently supports the sentencing considerations relied upon. A sentence of 14 months' imprisonment for a single-punch grievous bodily harm offence causing jaw detachment, where the offender has prior violent convictions and the assault was unprovoked on a vulnerable victim, falls within the customary range.
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