Grounds of appeal against sentence framed as complaints about inadequate weight given to particular factors are treated as raising manifest excess and require House v R error. The De La Rosa principles on mental health and sentencing do not operate as presumptions; a causal connection between mental illness and offending must be established by evidence before moral culpability can be reduced. The Bugmy principle that childhood deprivation must be given full weight does not mandate a reduction in moral culpability in every case. Provocation is not available as a mitigating factor where the offender left the scene, armed himself, and returned to confront the victim.
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