The Court of Criminal Appeal confirmed that there is no requirement for a sentencing judge to place the objective seriousness of a standard non-parole period offence on a putative range; it is sufficient to identify the facts, matters and circumstances bearing on the gravity of the offence, and it is neither an error to locate seriousness on a range nor an error to fail to do so. The Court also held that indicative sentences that are 'arguably high' by reference to JIRS statistics and like cases do not, without more, establish that an aggregate sentence is manifestly excessive. The failure to specify the precise degree of accumulation and concurrence in an aggregate sentencing exercise does not constitute error provided the totality principle is not demonstrably misapplied.
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