The factors identified in R v Gent for assessing objective seriousness of possession or importation of child pornography — nature and content, number of items, whether for distribution, and whether for profit — apply equally to offences of producing child pornography under s 91H(2). Where child pornography is produced from imagination (drawings and text, not photographs), is not produced for distribution, and involves no exploitation or victimisation of any actual child, the objective seriousness falls near the bottom of the range.
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