A Palmer direction is not required where complainants' rhetorical questions ('why would I lie') are not repeated by the prosecutor or trial judge, and where the prosecution's submissions address the improbability of collusion rather than the absence of motive to lie. A sentence may infringe the totality principle without being 'crushing' — the total effective sentence must be proportionate to overall criminality and no more than necessary to satisfy sentencing objectives. Delay in prosecution that is not attributable to the accused must be given mitigatory weight at sentencing, both as to rehabilitation and fairness, even in cases of historical sexual offending.
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