Where the same sentencing judge sentences all co-offenders in a criminal enterprise, carefully compares their cases, and provides reasons for differentiating between them, considerable obstacles face an applicant contending parity error on appeal. The parity principle applies even where co-offenders are charged with different offences, but the greater the difference between the charges, the greater the practical difficulties in comparison. A 2-1 split in this case demonstrates that reasonable minds may differ on whether differentiation is adequate even where the sentencing judge has been careful.
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