An aggregate sentence of 17 years for intra-family sexual abuse involving three victims over 13 years, without physical cruelty, pregnancy or disease transmission, and with a guilty plea, was manifestly excessive when the worst-category case of Podirsky attracted only 18 years after a contested trial. A sentence of 13 years was substituted. The Podirsky cases remain the benchmark for the worst category of intra-family sexual abuse in Western Australia.
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