Where no reliable sentencing range for the time of offending can be established due to a dearth of statistical information, the sentencing court may approach the task by assessing the nature of the criminal conduct against the maximum penalty prescribed at the time, following the Moon/MJR methodology. Delay in reporting intrafamilial sexual abuse, particularly by a father against his daughter, is significantly less consequential than in other sexual assault cases. The question whether the abolition of remissions under the Sentencing Act 1989 must be taken into account when sentencing for pre-1989 offences remains unresolved.
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