Where there are several victims of child sexual abuse, a failure to accumulate sentences at least partially may be seen as a failure to acknowledge the harm done to individual victims. There is a special need to ensure a proper level of accumulation to guard against a view that there is virtually no penalty imposed for offences against one or more victims. The Cahyadi principles on accumulation, concurrency and totality must be read with additional considerations applicable to crimes of violence and sexual assault involving multiple victims. The description of a sentence as 'crushing' does not articulate an applicable test.
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