Actual imprisonment remains the usual sentence for indecent treatment of children under 12, even where the offender pleads guilty and has no prior criminal history. However, an aggregation of mitigating factors — including voluntary counselling, church excommunication, cooperation, and reconciliation — may in a borderline case amount to exceptional circumstances justifying a non-custodial sentence. The borderline character of a case increases the Court of Appeal's reluctance to interfere on an Attorney-General's appeal.
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