Cases involving sexual offences against very young, unconscious children by persons in positions of trust are to be assessed on their own facts and are not to be equated with cases involving forced penetration of conscious, struggling children, even though both involve serious breaches of trust. The overall criminality approach requires consideration of both head sentence and parole eligibility date together, and the recording and distribution of child exploitation material significantly aggravates the sexual offending.
The full text is available to signed-in members, including the 7 later cases that cite this judgment.
2 of the 7 citing cases carry a classified treatment. How each court treated it is available to signed-in members.