A late amendment to a count in an indictment that changes the particular of the offence in a material way (here, from digital penetration to cunnilingus) cannot be made without recalling the complainant for further cross-examination, as there is no obligation on the defence to anticipate such an amendment. The effective head sentence of 8 years for 10 sexual offences against a child aged 8-9 by a de facto father was not manifestly excessive.
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