Where an offender's personality disorder is caused by childhood deprivation, both the Bugmy principles (deprivation reducing moral culpability) and the Verdins principles (impaired mental functioning reducing moral culpability) may be applied without constituting impermissible 'double counting', as each frame of reference has its own explanatory work to do. The relevance of childhood deprivation to moral culpability under Bugmy does not depend on proof of a causal nexus between the deprivation and the offending. A Crown appeal seeking life imprisonment will fail where the expert evidence supports fair prospects of rehabilitation with appropriate treatment, even where the offending is of the highest objective gravity.
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