Sentences for very serious gang-related firearms offences (s 33A(1)(a) Crimes Act 1900) may be lenient but not manifestly inadequate where the offenders acted under duress from gang leaders, were relatively young, came from deprived backgrounds, and provided exceptional assistance to authorities. The extent of childhood deprivation may moderate the weight given to deterrence in favour of rehabilitation even for very serious offences, applying Bugmy v The Queen. Non-exculpatory duress arising from gang membership, where the offender voluntarily joined but was threatened with death for non-participation in specific offences, is a mitigating factor under s 21A(3)(d).
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