A total effective sentence of 21 months imprisonment with release after 15 months for mid-range child pornography offences involving over 3,000 images and 77 videos was upheld as moderate rather than excessive. The 60-66% ratio of non-parole period to head sentence for Commonwealth offences is a general guide, not a statutory ratio, and may be disturbed by accumulation with State sentences without error. Partial accumulation is appropriate where Commonwealth and State child pornography offences are different offences committed over different timeframes.
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