The test for manifest inadequacy on Crown appeals against sentence in Victoria remains as stated in DPP v Karazisis: whether it was open to the sentencing judge, acting reasonably, if proper weight had been given to all relevant circumstances, to come to the sentencing conclusion reached. The High Court's decision in HT v The Queen did not add a further requirement of establishing 'an affront to the administration of justice'. For unlawful and dangerous act manslaughter involving the deliberate firing of a weapon, the objective gravity is to be assessed as high, and protracted concealment of the body and lies to police are significant aggravating features.
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