In manslaughter cases involving post-offence conduct, the denial of medical treatment to an injured victim and the concealment of the victim's body are each very serious aggravating features that must be given substantial weight in the sentencing exercise. The disposal of a victim's body is per se a significant aggravating feature and is emblematic of a complete lack of remorse. Courts should be cautious in applying Verdins principles where the causal nexus between a personality disorder and the offending is difficult to separate from co-existing substance use disorders.
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