When sentences are cumulated across different courts, the sentencing judge must consider whether the accumulation itself gives rise to special circumstances under s 44(2) of the Crimes (Sentencing Procedure) Act 1999 (NSW), requiring adjustment of the non-parole period to maintain the statutory ratio across the total sentence. The case also confirms that manslaughter by sexual assault of a very young child causing death falls within the worst category of manslaughter, justifying a sentence at or near the statutory maximum.
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