1Where a contract killing murder falls towards the worst category of the offence, the relative youth of offenders (early twenties), absence of prior violence convictions, realistic rehabilitation prospects, and harsh custodial conditions (prolonged isolation) may collectively justify a very lengthy determinate sentence rather than life imprisonment, applying the principle in R v Lowe [1997] 2 VR 465 that a life sentence is disproportionately punitive for younger offenders compared to older ones
2The public setting of a planned killing, while not separately charged as conduct endangering bystanders, is a significant aggravating feature of the murder itself, as the trauma inflicted on witnesses may properly be taken into account in assessing the gravity of the offence
3Disparity in non-parole periods between co-offenders who played equivalent roles in the offending may be justified by differing subjective circumstances, including one offender's commission of the offence while on bail, parole and subject to a firearms prohibition order, and the other's psychological vulnerability and likely deportation
