Features inherent in the offence of conspiracy to murder — such as intention to kill, premeditation, commission in company, and use of weapons — do not necessarily aggravate the seriousness of a conspiracy offence, and 'unifying principles' derived from murder sentencing cases do not directly assist in sentencing for conspiracy to murder. The residual discretion on Crown appeals may be exercised where delay and demonstrated rehabilitation make the case unsuitable as a vehicle for establishing sentencing principles.
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