For intra-familial sexual offences involving digital penetration by a first offender in a position of trust, a total sentence equivalent to 8 years and 3 months under the pre-transitional regime (5 years 6 months post-transitional) is manifestly excessive; 4 years' imprisonment (post-transitional) was the appropriate total sentence. There is no rigid hierarchy of sexual penetration for sentencing purposes; the seriousness of the offence depends on all the circumstances.
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