There is no general rule that a non-parole period must constitute a 'significant' or 'substantial' part of the head sentence; the appropriate relationship depends on the circumstances of the particular case and cannot be assessed by reference to a mathematical ratio. Where the Crown fails to make submissions on a relevant sentencing factor at first instance, it will ordinarily be precluded from raising that issue on appeal, though this failure alone may not warrant exercise of the residual discretion to decline to intervene.
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