An aggregate sentence of 12 years imprisonment with a 9-year non-parole period for a sustained course of domestic violence including assault occasioning actual bodily harm, reckless wounding, detaining for advantage, and witness intimidation offences was upheld as within the legitimate bounds of sentencing discretion. The finding of special circumstances under s 44(2) of the Crimes (Sentencing Procedure) Act 1999 (NSW) remains discretionary and is not compelled by the existence of features that might support it.
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