100 Appellant's counsel, Mr Karstaedt, in the written submissions in this appeal particularly pointed to the factors in the former s 89(2)(a) and (b) of the seriousness and nature of the offences and circumstances of the offences, having regard to the facts put forward by the defence as indicated above. In those submissions he also referred to the former s 89(2)(c), Messiha's antecedents, his "relatively minor record" and the fact he had not been previously sentenced to imprisonment. Mr Karstaedt's submissions also referred to the former s 89(2)(d) and the youth of the appellant, as well as the consideration that without parole he would emerge from prison with no supervision and was a person with a history of drug problems, in the context of a pre-sentence report where the conclusion stated that the appellant "appears to require greater supervision". Finally, Mr Karstaedt's submissions also addressed the former s 89(2)(e), "any other reason the court decides is relevant", by reference to positive signs of rehabilitation, being that the appellant's family stood behind him, his marriage of seven years, his two small children and the assistance of his brother, a security officer, towards his rehabilitation. Reference was also made in this connection to the fact that Messiha had, on all previous occasions, completed the community work components of the community-based orders, while the pre-sentence report had stated there was stability in the extended family situation, the prosecution had not submitted that parole should be refused, or that imprisonment should be imposed, and that the pre-sentence report did not contain a recommendation for any particular disposition, but rather had suggested the greater supervision referred to, and stated that if a custodial sentence were considered appropriate, Messiha "may be a suitable candidate for parole".