Where multiple sexual offences arise from a single episode, a sentencing judge must still have regard to the separate criminality of each offence and impose some degree of accumulation, even where all offences occurred at the same location on the same occasion. Fixed terms cannot be imposed for offences attracting standard non-parole periods. On re-sentencing to correct structural errors, the court may find special circumstances and adjust non-parole periods to maintain the same effective overall sentence where the original sentencing response was otherwise appropriate.
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