Non-penetrative sexual assaults by a medical practitioner involving rubbing of clothed genitals against patients during examinations, taken individually, warrant head sentences in the range of 12 to 18 months imprisonment. While the totality principle permits increasing the sentence on one count to reflect overall criminality including breach of trust, number of victims, and protracted offending, the increase must remain proportionate to the actual offences committed. A head sentence of three years imprisonment was appropriate for nine such offences against six complainants over a six-year period.
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