A sentencing judge may properly adopt a starting point for sentence by reference to co-offenders sentenced for offences committed on different dates and against different complainants, provided the offences are of comparable objective gravity. The circumstances of an act of fellatio may place it at a position on the spectrum of sexual intercourse offences consistent with penile-vaginal intercourse, such that parity comparisons across different forms of sexual intercourse are permissible. No disparity arises where a co-offender receives the same head sentence with Form 1 offences taken into account, if the sentencing judge did not increase the sentence beyond what was appropriate for the primary offence alone.
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