A failure to indicate a non-parole period for an indicative sentence for a standard non-parole period offence within an aggregate sentence does not constitute error requiring appellate intervention, as it has no capacity to influence the aggregate sentence. The question whether a fixed term under s 45 equates to the non-parole period or the head sentence remains unresolved, though the Court noted the statement in R v Dunn may require reconsideration in light of the 2016 amendments inserting s 45(1A) and (1B).
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