Rapid rehabilitation from drug addiction within less than one year, combined with maintained employment, a difficult early life, and offending within a relatively closed period, can constitute 'exceptional circumstances' under s 54(2) of the Sentencing Act 2017 (SA) sufficient to displace the mandatory minimum non-parole period of four-fifths for serious repeat offenders. The question whether s 54(2)(a) elevates personal and general deterrence to paramount considerations (as held in R v Karnage) or whether they remain secondary purposes under ss 3, 4 and 9 of the Act was expressly left open for future determination.
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