An aggregate sentence of 16 years for two sets of serious intra-familial sexual offences against two stepdaughters, imposed by different judges, was reduced to 14 years on totality grounds, with the second set of sentences ordered to commence after service of 6 years of the first. The case confirms that the range of 10 to 19 years identified in VIM applies after trial for very serious repeated sexual offending representative of a course of conduct. The examples in the table to s 94 of the Sentencing Act 1995 (WA) conflict with s 93 due to a legislative oversight, and s 7(2)(b) of the Sentence Administration Act 2003 (WA) should be interpreted so that partially concurrent terms overlap by reference to the full parole terms, not the non-parole periods.
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