While extended joint criminal enterprise may as an abstract proposition involve less culpability than direct participation in murder, the individual facts — particularly the offender's knowledge of the co-offender's violent tendencies and continued participation after witnessing extreme violence — may support a finding of objective seriousness well above the mid-range. When challenging an aggregate sentence, it is insufficient to focus on one indicative sentence; the applicant must demonstrate that the aggregate sentence as a whole is manifestly excessive. A sentencing judge is not required to consider matters as giving rise to special circumstances in the absence of specific submissions to that effect.
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