Where multiple sexual offences are committed against the same victim in a single episode, each offence involving a separate violation constitutes a separate offence and transaction meriting cumulative sentences, subject to the totality principle. The failure to follow the Pearce methodology of fixing individual sentences before considering cumulation does not vitiate the sentencing exercise where no concealment of error results. A head injury causing organic personality disorder and frontal lobe syndrome, while relevant to sentencing, does not necessarily require reduction of sentence where the offender's substantial criminal history predated the injury.
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