The Pell v The Queen framework for appellate review of unreasonable verdict grounds applies by analogy to judge-alone trials. Out-of-court denials by an accused in a police interview, being unsworn and untested by cross-examination, may properly be characterised as 'bare denials' and given limited weight where the trial judge has accepted the complainant's sworn evidence as credible and reliable. Sentences of immediate imprisonment for serious child sexual offences committed by a juvenile are not manifestly excessive as to type merely because the offender has good personal circumstances and antecedents, where the objective seriousness of the offending decisively outweighs mitigating factors.
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