Abstinence from further offending alone is insufficient to establish progress towards rehabilitation for the purposes of the rehabilitation limb of delay; there must also be evidence of remorse and reform. Sentencing Advisory Council statistics are of limited utility for offences of obtaining financial advantage by deception given the wide range of circumstances that may give rise to the offence. A total effective sentence of 5 years and 3 months' imprisonment for obtaining approximately $382,400 by deception from family members over nearly three years, with relevant prior criminal history and no remorse, was within the range open to the sentencing judge.
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