• The appropriate range for the offence of manslaughter by means of failing to provide the necessaries of life is 7 to 16 tears, with 16 years being the upper end of the range for cases involving ongoing horrendeous and fatal abuse of persons by individuals responsible for their care: R v Hawley, 2016 ONCA 143 at para 6-7

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• However, in a particularly egregious case, a sentence of 20 years may nontheless be fit: Hawley at paras 9-11