49 esp at para [12]. There has recently been a considerable tightening up in what the CCA is prepared to recognize as special circumstances. Where there are a number of sentences imposed, and the overall sentence produces a non-parole period which is more than 75% of the head sentence, if no reasons are given, error may have been established: Flynn v Regina [2010] NSWCCA 171 esp at para [44]. This will especially be the case if the judge finds special circumstances : Maglis v Regina [2010] NSWCCA 247 . In Barret v Regina [2011] NSWCCA 211 where the sentencing judge found no special circumstances but imposed an overall non-parole period which was 83% of the head sentence the CCA found that there was error. In Mattar v Regina [2012] NSWCCA 98 where the he judge imposed cumulative sentences producing an overall head sentence with an overall non-parole period of 90% of the head sentence, error was established (see esp. para [25]). In Lewis (1998) 100 A Crim R 361 the CCA said what was needed was something that meant a longer period of parole was needed (such as rehabilitation) or imprisonment would be especially harsh such as protection. The CCA has pointed out that it will be a rare case in which there is no fact which could not as a matter of law constitute special circumstances: Regina v Simpson (2001) 53 NSWLR 704 esp at para [73]. 'Special circumstances' are not limited to the question of whether or not