A selection of four or five comparable cases where sentences were lower does not establish a sentencing range or demonstrate manifest excess; it merely shows that in those cases the sentences were within the appropriate range. For Commonwealth offences, there is no requirement to specify where on a scale of seriousness the offending falls, as may be required for standard non-parole period offences under NSW law. Where counsel concedes the relative seriousness of an offence, the sentencing judge is not required to make further express findings on that point.
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