Where a sentencing judge records a conviction against a juvenile without articulating reasons or referring to the s 184(1) YJA considerations, the appellate court will proceed on the basis that the discretion miscarried and exercise it afresh. The case confirms that escalating criminality, disregard for court orders, significant criminal history, and absence of evidence about employment impact can justify recording convictions. The case also provides early guidance on s 299A publication prohibition orders, applying the same balancing approach to the enumerated factors. Where an appellate court would impose the same sentence on re-exercise of discretion, the proper course is to grant leave but dismiss the appeal under s 668E(3) to avoid resetting the rehabilitation period under the Criminal Law (Rehabilitation of Offenders) Act 1986 (Qld).
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