The emotional harm inherent in sexual assault offences cannot be treated as a separate aggravating factor under s 21A(2)(g) without evidence of harm significantly beyond what is to be expected from the commission of such offences. An adult victim of sexual assault is not 'vulnerable' within the meaning of s 21A(2)(l) merely because the offence occurred late at night. A prior criminal record that does not demonstrate a continuing attitude of disobedience or reveal moral culpability cannot be treated as an aggravating factor under s 21A(2)(d), consistent with Veen (No 2).
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