The parity principle does not apply where the relevant offending by a related offender was placed on a Form 1 rather than being the subject of a separate sentence, because there is no relevant comparison between a sentence imposed for an offence and an unspecified increase in a sentence for another offence by reason of the Form 1 offence being taken into account. Counsel at sentence hearings should provide sentencing judges with JIRS statistics and comparable cases to avoid avoidable appeals.
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