Where a sentencing judge makes an express finding of special circumstances and varies the statutory ratio for individual sentences, the effect of accumulation on the overall ratio must be addressed. A variation of only 1.7% from the statutory ratio (73.3% vs 75%) cannot be described as a 'moderate' variation and, absent explanation, will be treated as an oversight. The Bugmy principles require full weight to be given to a deprived background in every sentencing decision, but this does not mean moral culpability must be reduced in every case.
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