Where a non-citizen offender faces near-certain deportation and has an Australian citizen child who has been sent overseas due to the offender's incarceration, the combination of these circumstances may constitute exceptional circumstances enlivening the discretion of mercy. The parity principle requires amelioration of disparity even where the co-offender's sentence is manifestly inadequate, but the applicant's sentence cannot be reduced to a point where it is itself manifestly inadequate.
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