A sentence of 16 years imprisonment (with serious violent offence declaration requiring service of 80 per cent) for the rape of a 21-month-old child, where the offending was in the worst category, was not manifestly excessive. A psychiatric report diagnosing polysubstance abuse and major depressive episode at the time of offending will not necessarily have mitigating effect where the offending involves extreme sexual violence against a very young child. In cases of sexual violence against infants, the mode of penetration (penile versus digital) is of limited relevance to sentence.
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