Where a sentencing judge makes multiple errors in the exercise of the sentencing discretion — including taking into account matters not in the agreed facts, double counting elements of the offence as aggravating factors, and making findings unsupported by evidence — the cumulative effect of those errors may require appellate intervention even where individual errors might not. The location of sexual offences in the family home is not a separate aggravating factor where the breach of trust arising from the familial relationship has already been taken into account. The ages of victims cannot be treated as aggravating factors where age is an element of the offence charged, unless the victims are well below the stated age range and the evidence supports that finding.
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