A sentencing judge may refer to the potential lethality of strangulation when assessing the seriousness of the criminality of a strangulation offence; such a reference does not constitute sentencing for potential future harm. A head sentence of 3 years imprisonment for strangulation in a domestic setting, inflated to reflect the total criminality of a series of domestic violence offences over four hours including use of cane knives, with parole after one-quarter, was within the permissible range.
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