The Pfennig test for admissibility of similar fact evidence is satisfied where the accused's prior sexual offending against a child reveals a pattern of befriending a male child, engineering bed-sharing, using massage as a pretext for sexual grooming, and progressing from touching to fellatio to sodomy, even where there are differences in the ages and vulnerabilities of the complainants and a 10-year gap between offences. Where a concurrent sentence has no practical consequence, an applicant for leave to appeal against that sentence must do more than merely assert it is too high.
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