The sentencing range for multiple counts of incest involving young children in Victoria, even in cases of extreme gravity involving breach of trust and very young victims, is generally in the order of 8-12 years total effective sentence where there is a plea of guilty. Individual sentences of 12 years for a single count of incest are outside the permissible range. The Court endorsed the principles in Hudson v The Queen regarding the limited use of comparable cases as sentencing guides.
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