The case confirms that incest offences involving an intellectually disabled adult victim over a six-week period, resulting in pregnancy, but without violence, threats, or offending against young children, do not fall into the worst category of incest. Individual sentences of three years for such offences fall at the lower end of the available range. Sentencing judges should ordinarily explain departures from the presumption of cumulation under s 6E of the Sentencing Act 1991 when sentencing serious sexual offenders. The question whether current sentencing practices for incest are adequate remains open for future challenge.
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