Sentences of 22 years for murder are generally reserved for cases unattended by powerful mitigating features; where an offender has a major depressive disorder impairing mental functioning, extreme background of disadvantage, likelihood of deportation, protective custody, and the principle of mercy applies, significantly more lenient sentences are required even for the most objectively grave offending. Where multiple offences arise from a single act, cumulation should be moderate. A sentencing judge's acknowledgment that mercy is 'significant' must be reflected in the sentence actually imposed.
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