The higher sentencing standards for child sexual offences established in R v D (1997) 69 SASR 413 apply only to offences committed after that decision, not retrospectively. Applying increased sentencing standards to pre-existing offences amounts to a retrospective change requiring good grounds to justify. The totality principle is not a routine basis for sentence reduction and will usually have little part to play when a single sentence is imposed under s 18A.
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