An agreed statement of material facts tendered on sentencing does not exclusively and exhaustively constitute the factual basis for sentencing; both prosecution and defence may assert additional facts not inconsistent with the agreed facts, and the court is not bound by the parties' agreement as to the factual basis. The statement that general deterrence is the dominant sentencing factor in arson cases is not an error of principle. Sentencing patterns for arson in Western Australia are yet to emerge following the increase in maximum penalty to life imprisonment.
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