A sentence of 2 years 6 months' immediate imprisonment for a single-punch grievous bodily harm offence causing a broken jaw was upheld where the punch was powerful, delivered without warning to a vulnerable victim on the ground, and the offender was significantly larger than the victim. The expression 'parental care' in the hardship-to-family sentencing principle is to be understood broadly to include care by relatives or other persons able to undertake parental duties. An appellate court retains discretion to refuse leave to appeal on a ground alleging express sentencing error if satisfied that no different sentence should have been imposed.
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