General deterrence is a very important consideration in sentencing for offences of violence committed in the course of domestic disputes, and sentences that fail to reflect the brutality of such offending will be increased on Crown appeal. A guilty plea discount must not exceed the statutory maximum available for the most serious offence, and the inevitability of a guilty plea is relevant to the discount given. The 'rare and exceptional circumstances' test for Crown appeals requires identification of the underlying principle — whether the sentence is so far below the appropriate range that allowing it to stand would shake public confidence in the administration of justice.
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