Evidence of acts of violence committed by an accused against other members of the complainant's family within the domestic environment is admissible in sexual offence prosecutions as relevant to the relationship between the parties and the complainant's submission to sexual exploitation through fear. A sentence of 10 years for rape of a stepdaughter where offending began at age 8 and spanned 6 years was manifestly excessive; 8.5 years was substituted as appropriate.
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