Where the statutory maximum for a sexual offence is relatively low, a greater range of cases will call for the application of the maximum or something close to it, and a sentence that is a high proportion of the maximum does not of itself betoken error. Total cumulation on representative counts may be appropriate where the counts represent different types of offending evidencing a progression in seriousness. An erroneous classification as a serious sexual offender does not vitiate the sentence where the judge expressly did not rely on the special provisions.
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