An individual count of indecent dealing should not be divorced from its context within an escalating course of sexual offending against a child; conduct characterised as grooming justifies a higher sentence for that count. Where conventional accumulation of sentences for multiple sexual offences against a child would produce a significantly higher total, a sentence reduced by application of the totality principle is not disproportionate merely because it exceeds sentences in other cases with distinguishing features such as voluntary disclosure.
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