Where a co-offender's sentence is reduced on appeal, the remaining co-offender may have a justifiable sense of grievance if the reduction disturbs the proportionality between their sentences, even where the error related to a subjective factor personal to the co-offender. The parity principle is not confined to the offender who received the more severe sentence. However, the scope for reduction may be limited where the objective gravity of the offending means any further reduction would produce a manifestly inadequate sentence. The question whether an erroneous sentence overturned on appeal can give rise to a justifiable sense of grievance remains contested, with Basten JA's dissent providing a principled basis for the contrary view.
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