offence described in Henry : Regina v Kelly [2010] NSWCCA 259. Robberies can be regarded in escalating seriousness with the carrying of a firearm, the firearm being loaded, the weapon being fired, and the weapon being aimed at someone while fired: Readman (1990) 47 A Crim R 185. It has been held that it is 'slightly' overstating the case to say that there must be a custodial sentence for robbery except in exceptional circumstances, although generally a custodial sentence will be appropriate: Fraser [1999] NSWCCA 212 . Firearms Offences In sentencing for selling firearms it is permissible to take into account the fact that the offender must have known that the weapons would be used in an illegal activity: KC v Regina [2009] NSWCCA 110 . Escape. The head sentence for an unremarkable escape was held to be 2 years in Regina v Thompson (NSW CCA u/r 21/5/86) and Stuart (1990) 47 A Crim R 293, but see Sinnett (1996) PD [134] and Steff (1997) 96 A Crim R 1. Later cases have said that the 2 year period is no a minumum and sentences as low as 6 months have been upheld: see Regina v Robinson [2000] NSWCCA 182 esp at para [29] and Regina v Horne [2004] NSWCCA 8 esp at para [37]. An appeal against a sentence of 2 years with a non-parole period of 18 months for an 'unremarkable escape' was rejected in Mihail v Regina [2010] NSWCCA 104 . The sentence must be cumulative: s.