- Pehar v R  NSWCCA 118
- Ford v R  NSWCCA 99
Aggravating factors on sentence – ‘in company’ – aggravation not established by mere presence
The Court of Criminal Appeal (‘CCA’) has confirmed that an offence is not aggravated merely because another person is present ‘in company’ with the offender. For the statutory aggravating factor to be engaged, there must be a principled explanation as to why the presence of another person renders the offence more serious.