Following Hili, a non-parole period of 75 percent of the head sentence for Commonwealth offences, while historically regarded as high and potentially punitive, is not erroneous where the head sentence and non-parole period are each independently justified on the facts. A sentencing judge is not required to give specific reasons for the ratio chosen. Delay in prosecution that is 'substantial and really inexcusable' and not attributable to the offender must be taken into account, but a sentencing judge is not required to use specific terminology such as 'uncertain suspense' to demonstrate that delay has been considered.
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