Where two sexual offences are committed against the same victim by the same offender within an ongoing relationship, the sentencing judge must consider the significant elements of commonality between the offences — including the nature of the relationship, the nature of the conduct, and the offender's subjective case — when determining the degree of accumulation. A sentencing judge who makes non-parole periods entirely cumulative based solely on the offences being discrete and separated in time, without considering these factors, falls into error. Where Form 1 offences create overlap between the factual bases of two counts, this provides a strong basis for partial concurrence.
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