A single prior conviction of the same kind as the offence being sentenced does not automatically constitute an aggravating factor under s 21A(2)(d); the sentencing judge must consider whether it is significant and, if so, must apply the Veen (No 2) principles to determine the proper use to be made of it. Where the prior conviction is dated, resulted in a minor penalty, and the circumstances of the present offending are amply established without resort to it, the prior conviction may properly be treated as neutral — neither aggravating nor mitigating. A sentencing judge who treats a prior conviction as aggravating must give adequate reasons, particularly where the question of significance is genuinely contestable.
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