A sentencing judge may refer to an offender's prior conviction for domestic violence against the same victim when describing the domestic relationship context relevant to objective seriousness, provided the prior conviction is separately and expressly treated as an aggravating factor diminishing entitlement to leniency under s 21A(1)(d). Reliance on sentences imposed in other cases to establish manifest excess must demonstrate inconsistency in the application of sentencing principles, not merely numerical disparity.
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