A prior conviction for murder, particularly where the circumstances of the prior offence are similar to the current offending (both arising from trivial disputes), is an important aggravating feature that emphasises the need for specific deterrence and community protection, and can justify a sentence at the upper end of the range for manslaughter. Sentencing statistics showing a lower median non-parole period do not, of themselves, demonstrate that a sentence is outside the range reasonably available.
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