The case confirms that sentences for child pornography offences involving images at the lowest levels of the COPINE/Oliver scale, where the offender lacked subjective appreciation of criminality and cooperated fully, may fall at the very bottom of the sentencing range without being manifestly inadequate. The proceeds of crime offence arising from the same commercial enterprise as carriage service offences requires substantial concurrence to avoid double punishment where the financial gain has already been treated as an aggravating factor in the carriage service offences.
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