Emotional harm for the purposes of s 21A(2)(g) of the Crimes (Sentencing Procedure) Act 1999 is not limited to the victim's immediate physical or emotional reaction to the assault itself; it extends to foreseeable consequences including disruption to family relationships following a complaint. A position of trust under s 21A(2)(k) is not limited to parental or spousal relationships and can arise from de facto family-like relationships such as that between an offender and his partner's younger sibling.
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