R v Comber

Decided: 2026-08-31. Citation: 2026 MBCA 75 (CanLII). Criminal and statutory offences — Sentencing — Manslaughter — Firearm — Court of Appeal imposing sentence under Criminal Code, s. 686(3)(b) — Sentence warranted in law for manslaughter after verdict substituted — Proportionality, denunciation and deterrence emphasised for reckless discharge — Twelve years’ imprisonment imposed, with credit for pre-sentence custody | Criminal and statutory offences — Sentencing methodology — Starting-point approach — Manslaughter with a firearm — Whether starting point of ten years appropriate for cases closer to murder than accident — R v Parranto framework applied, aggravating and mitigating factors weighed — Offence characterized as extremely serious and highly blameworthy — Twelve years’ imprisonment