An aggregate sentence must be supportable by a reasonable construction of the sentencing judge's remarks on accumulation and concurrency of indicative sentences; where it is not, the aggregate sentence is affected by error. Indicative sentences under s 53A(2)(b) are not themselves amenable to appeal but may be suggestive of error in the aggregate sentence. For child abuse material offences, the fictional nature of material does not necessarily render production and dissemination less serious, and limited distribution via SMS does not mitigate where the recipient is a known paedophile with potential to disseminate further.
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