The case reaffirms that personal and general deterrence have heightened significance when sentencing for domestic violence offences, and that a sentencing judge is entitled to assess rehabilitation prospects as extremely poor based on a long criminal history of violence and non-compliance with orders, without being required to obtain current psychological or correctional reports. A forensic decision not to obtain updated reports for sentencing will preclude reliance on the first Dorning criterion for fresh evidence on appeal. A non-parole period of approximately 72% of the head sentence is not manifestly excessive where deterrence, prevention and punishment considerations are strong and rehabilitation prospects are poor.
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