The sentencing principles in Hogarth v The Queen (2012) 37 VR 658 regarding the seriousness of aggravated burglary and the inadequacy of prior sentencing practices apply to all categories of aggravated burglary involving home invasion with animosity and intended confrontation, including 'intimate relationship aggravated burglaries'. Confrontational aggravated burglary is not necessarily more objectively serious than intimate relationship aggravated burglary. General deterrence remains a paramount sentencing consideration for intimate relationship aggravated burglaries.
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