A serious assault suffered by an offender while in custody at the hands of a correctional officer, and the ongoing consequences of that assault and of giving evidence against the officer (including being labelled a 'dog', placed on special management, frequent transfers, and denial of access to programs), are powerful subjective factors that may render a sentence manifestly excessive if insufficiently weighted. A ground of appeal alleging insufficient weight given to a particular sentencing factor remains narrowly confined and requires demonstration of House v The King error.
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