The disposal and concealment of a victim's body constitutes a significantly aggravating circumstance of manslaughter, distinct from and additional to its relevance to the question of remorse. An offender's refusal to disclose how the victim was killed, combined with a protracted course of lies and deceit, demonstrates a complete absence of remorse — the absence of a mitigating factor that often significantly mitigates sentence. The inability to determine the mechanism of death (caused by the offender's own concealment) does not preclude a finding that the overall offending is very serious when assessed by reference to all known circumstances including post-offence conduct. The domestic setting of a homicide remains a significant aggravating feature even where there is no history of prior domestic violence.
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