There is no automatic discount for delay in sentencing; the reasons and circumstances surrounding any delay must be examined in each case. The complexity of an investigation and volume of material may justify a period of delay that would otherwise be considered extraordinary and inordinate. Where a sentencing judge has had regard to a prosecution MacNeil-Brown range submission (made before Barbaro v The Queen), the appeal will fail if the appellate court is not persuaded that any different sentence should have been imposed.
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