The facts and circumstances of related offences committed closely in time can be relevant to assessing the objective seriousness of a subject offence in two ways: (1) prior offences may establish the victim's increasing vulnerability known to the offender, affecting the seriousness of subsequent offences; and (2) where the offender premeditated all offences from the outset, the intention to commit further and more brutal offences aggravates the seriousness of the earlier offences. RO v R and Singh v R do not establish a blanket prohibition on considering related offences in assessing objective seriousness.
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