A sentencing judge's observation that a child victim had no place of safety to escape to when offences were committed in the family home by a step-parent does not constitute impermissible double counting under s 21A(2) of the Crimes (Sentencing Procedure) Act 1999, as it is a natural incident of the breach of trust inherent in such offences. Voluntary disclosure of evidence to police is a relevant mitigating factor that must be given weight in sentencing for child pornography offences.
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