The principle in Bugmy v The Queen cautioning against looking too far into the future when setting non-parole periods is distinguishable where the offender's underlying disorder (here, sexual sadism disorder) cannot be effectively treated, unlike drug addiction where the offender is taking steps toward rehabilitation. A 35-year non-parole period on a life sentence for murder is not disproportionate where the untreatable nature of the disorder means that the passage of time alone does not diminish the relevance of community protection. The principle of parsimony is not infringed where the sentence falls within the available range of sentencing options.
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