In multi-complainant child sexual offence cases, sentences for offences against different victims must be appropriately accumulated to reflect the totality of criminality; making all sentences concurrent across victims effectively fails to punish the offender for offending against some victims. The Papakosmas principle that no error of law arises from failure to object may not apply to fundamental misdirections such as those concerning the burden of proof or the use of tendency evidence. Rule 4 of the Criminal Appeal Rules cannot limit an express statutory right of appeal under s 5 of the Criminal Appeal Act 1912.
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