A total effective sentence of 14 years for sexual offences against two children (aged 9 and 14) involving digital penetration and cunnilingus, committed by a recidivist offender with a prior 10-year sentence for similar offences, was reduced to 11 years as the individual sentences exceeded the applicable range. The sentencing patterns reviewed in Woods v The Queen (1994) 14 WAR 341 remain generally applicable to sexual assault cases in Western Australia, notwithstanding a 'firming up' of sentences in the District Court.
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