A sentencing judge who wholly accumulates a sentence on a pre-existing sentence (including balance of revoked parole), resulting in an overall non-parole period ratio exceeding 75%, does not necessarily err by failing to find special circumstances, provided the transcript and sentencing remarks demonstrate that the judge gave consideration to the impact of accumulation and was satisfied the non-parole period appropriately reflected the criminality of the offences. The case is distinguishable from GP v R where the sentencing judge did not turn her mind to the impact of accumulation.
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