The court expressed concern regarding the extent to which R v Frisby [2002] 1 Cr App R (S) 68 should be followed. Since the enactment of the Criminal Justice Act 2003 and the approach to be adopted when sentencing for murder, whereby the disposal of a body could form an aggravating feature, it was possible that the disposal of the body could also form an aggravating feature when sentencing for manslaughter offences.

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